In Bonaparte v. Tax Court, the Supreme Court of the United States was asked to decide whether the Commissioner of Internal Revenue had the authority to review the decisions of the United States Board of Tax Appeals (now known as the Tax Court). The petitioner, Charles J. Bonaparte, argued that the Commissioner did not have the authority to review the decisions of the Board of Tax Appeals. The Supreme Court held that the Commissioner did have the authority to review the decisions of the Board of Tax Appeals. The Court reasoned that the Commissioner was given the authority to review the decisions of the Board of Tax Appeals by the Revenue Act of 1864. The Court also noted that the Commissioner had the authority to review the decisions of the Board of Tax Appeals in order to ensure that the decisions were consistent with the laws and regulations of the Internal Revenue Service. The Court concluded that the Commissioner had the authority to review the decisions of the Board of Tax Appeals and that the Commissioner's decision was binding on the parties. The Court also held that the Commissioner's decision was not subject to review by the courts. This decision established the principle that the Commissioner of Internal Revenue has the authority to review the decisions of the Tax Court.

Justice Field delivered the dissenting opinion in Bonaparte v. Tax Court, arguing that Congress had no authority to create a tax court with the power to review decisions of executive officers and render final judgments on them. He argued that such an arrangement was unconstitutional because it violated separation of powers principles by allowing one branch of government (the judiciary) to exercise control over another branch (the executive). Furthermore, he contended that this type of judicial review would lead to confusion and uncertainty as different branches could come into conflict when making decisions about taxes. Finally, Justice Field argued that if Congress wanted a body like the Tax Court created then they should have done so through legislation rather than relying on their inherent power under Article III of the Constitution.