2026-01-08
From 1997 to 2025, there have been 13,947 opinions published by the Tax Court. A total of 166 of these opinions (1.2%) were more than 80 pages long. Below is a histogram of the number of pages for the Tax Court opinions that were 80 pages or shorter. The average length of the opinions is 18 pages.
I have been experimenting with running some large language models (LLMs) locally on my computer. Assuming 4 characters per token, the average Tax Court opinion has about 6K tokens. The gemma3:4b LLM has a context length of up to 128K tokens. Therefore, gemma3:4b should be able to analyze nearly all Tax Court opinions. Tax Court opinions with 80 pages average about 27K tokens. (Apparently smaller LLMs, such as those with 4 billion parameters, are now being referred to as small language models, or SLMs.)
So far I have been impressed with the summarization capabilities of gemma3:4b. However, I still find LLMs wholly unreliable for tax research.
