The Tax Court May Issue an Opinion as a "Regular

The Tax Court may issue an opinion as a "Regular," as opposed to a "Memorandum" opinion, if

A) The amount at issue exceeds $25,000 ( for individuals, trusts and estates) or $100,000 (for all other taxpayers) .
B) The issue involves the Constitutional validity of any federal revenue-raising provision.
C) The Tax Court considers the case to be expressive of a new point not previously covered by one of its published decisions.
D) Both the taxpayer and the IRS petition for publication of the opinion as a "Regular" decision.