We revisit our prior decisions only when presented with a special justification to do so. Sec. State Bank v. Commissioner, 111 T.C. 210, 213 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000)

As an initial matter, the doctrine of stare decisis counsels us to "follow the holding of a previously decided case, absent special justification." Sec. State Bank v. Commissioner, 111 T.C. 210, 213 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000). Stare decisis "promotes the evenhanded, predictable, and consistent development of legal principles, fosters reliance on judicial decisions, and contributes to the actual and perceived integrity of the judicial process." Hesselink v. Commissioner, 97 T.C. 94, 99 (1991) (quoting Payne v. Tennessee, 501 U.S. 808, 827 (1991)).

As a trial court, we may depart from our own precedent if we have special justification for doing so. Sec. State Bank v. Commissioner, 111 T.C. 210, 213 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000). As a national court whose cases can be appealed in any one of the geographic circuits, we are not required to follow the precedent of circuits other than the one in which the present case is appealable.

Oakbrook's division opinion binds us. See, e.g., Sec. State Bank v. Commissioner, 111 T.C. 210, 213-14 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000). Burning Bush's deed would subtract the value of any improvements from any condemnation award before calculating what percentage of those proceeds would go to the donee.

We expressly rejected this argument in Pine Mountain, 151 T.C. at 280-81, and will follow that opinion here, as we must. See, e.g., Security State Bank v. Commissioner, 111 T.C. 210, 213-14 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000). We also note that the Commissioner, despite having appealed the issue in Pine Mountain, see Principal and Response Brief for Commissioner at 59, Pine Mtn. Pres., LLLP v. Commissioner, is no longer making this argument in litigated cases, see G.C.M. AM 2020-001 (Mar. 17, 2020).

Some of these examples thus lead to what may seem odd results, but we must nevertheless apply the Code as it is written and interpreted in a Division Opinion. See Sec. State Bank v. Commissioner, 111 T.C. 210, 213 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000); Hesselink v. Commissioner, 97 T.C. 94, 99-100 (1991); Nihiser v. Commissioner, T.C. Memo 2008-135, 95 T.C.M. (CCH) 1531, 1534 (2008). And there's one last thing to note--the variable Cd is not limited by tracing rules.

(the majority in Estate of Maxwell did not dispute this point)), aff'g 98 T.C. 594 (1992); Sec. State Bank v. Commissioner, 111 T.C. 210, 213-214 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000); Hesselink v. Commissioner, 97 T.C. 94, 99-100 (1991). This well-established feature of American courts, see, e.g., Hilton v. S.C. Pub. Rys. Comm'n, 502 U.S. 197, 202 (1991) ("Time and time again, this Court has recognized that 'the doctrine of stare decisis is of fundamental importance to the rule of law.' * * * [W]e will not depart from the doctrine of stare decisis without some compelling justification."

See Sec. State Bank v. Commissioner, 111 T.C. 210, 213 (1998) ("The doctrine of stare decisis generally requires that we follow the holding of a previously decided case, absent special justification."), aff'd, 214 F.3d 1254 (10th Cir. 2000).

" Sec. State Bank v. Commissioner, 111 T.C. 210, 213-214 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000); see also Hesselink v. Commissioner, 97 T.C. 94, 99-100 (1991); BLAK Invs. v. Commissioner, T.C. Memo. 2012-273, at *10. "Therefore, respondent bears the heavy burden of persuading us that we should overrule our established precedent."

This doctrine is of particular importance when the antecedent case involves statutory construction". State Sec. Bank v. Commissioner, 111 T.C. 210, 213-214 (1998), aff'd, 214 F.3d 1254 (10th Cir. 2000); see also Hesselink v. Commissioner, 97 T.C. 94, 99-100 (1991). Therefore, respondent bears the heavy burden of persuading us that we should overrule our established precedent.