Coverage disclosure
Coverage
Federal authority coverage
Athena’s authority chains are currently built from Tax Court authority. Federal appellate and district authority is not yet served in those chains.
Measured boundary
Measured 2026-08-10 across 31,754 citation-cache files and the published authority graph.
What this means for your research
A chain can accurately describe the Tax Court authority Athena serves and still omit a relevant federal appellate or district decision. Treat the chain as a Tax Court research starting point and check federal sources separately before relying on the absence of a federal authority.
Why Athena discloses this
An omission is recoverable only when it is visible. Athena keeps this boundary beside the research surfaces it affects so that an incomplete chain cannot be mistaken for a complete account of federal authority.
Tax Court citation capture (measured)
Even within Tax Court authority, citation capture is incomplete — and measured rather than assumed. Against an independent reference set built from the Caselaw Access Project (CAP), Athena currently captures 34.50% of comparable Tax Court–to–Tax Court citation candidates (19,308 of 55,966; measured 2026-08-09, adjudicated 2026-08-11).
Two limits on that number. The comparison reaches only the part of the corpus CAP also holds — 45.8% of Athena’s Tax Court cases, 83% of it decided before 1986 — so it is era-specific evidence, not a certification of the modern corpus. And about a third (31.3%) of the missed citations do not appear in the opinion text Athena holds, so they cannot be captured from the current corpus at all.
What this means for your research: an empty or short subsequent-treatment panel means not yet captured, never not cited. Verify subsequent treatment through a separate source before relying on its absence.