[1] Under the rule (referred to as the Golsen Rule) articulated in the case, the Tax Court may render different decisions, based on identical situations, for taxpayers that are differentiated only by the geographical area in which the Tax Court case is decided.

Jack E. Golsen of Oklahoma City purchased what was purportedly a whole life insurance policy from Western Security Life Insurance Co.

These courts of appeals may render different decisions for two distinct taxpayers, who have the same facts in evidence.

[5] An example of the practical effect of the Golsen rule is that if the Tax Court is hearing a case in Dallas, Texas, the Tax Court would follow the precedent of the United States Court of Appeals for the Fifth Circuit (which consists of Texas, Louisiana and Mississippi).

By contrast, if the Tax Court is hearing a case in Miami, Florida, the Tax Court would follow the precedent of the United States Court of Appeals for the Eleventh Circuit, as Florida is located in the Eleventh Circuit.