"On the Behrens–Fisher Problem: A Review" by Seock-Ho Kim and Allen S. Cohen
Journal of Educational and Behavioral Statistics, volume 23, number 4, Winter, 1998, pages 356–377
I'm looking at this thing and it says:
Fisher (1935, 1939) chose the statistic $$ \tau = \frac{\delta-(\bar x_2 - \bar x_1)}{\sqrt{s_1^2/n_1+s_2^2/n_2}} = t_2\cos\theta - t_1\sin\theta $$ [where $t_i$ is the usual one-sample $t$-statistic for $i=1,2$] where $\theta$ is taken in the first quadrant and $$ \tan\theta = \frac{s_1/\sqrt{n_1}}{s_2/\sqrt{n_2}}.\tag{13} $$ [ . . . ] The distribution of $\tau$ is the Behrens–Fisher distribution and is defined by the three parameters $\nu_1$, $\nu_2$, and $\theta$,
The parameters $\nu_i$ had earlier been defined as $n_i-1$ for $i=1,2$.
Now the things that are unobservable here are $\delta$ and the two population means $\mu_1$, $\mu_2$, whose difference is $\delta$, and consequently $\tau$ and the two $t$-statistics. The sample SDs $s_1$ and $s_2$ are observable and are used to define $\theta$, so that $\theta$ is an observable statistic, not an unobservable population parameter. Yet we see it being used as one of the parameters of this family of distributions!
Could it be that they should have said the parameter is the arctangent of $\dfrac{\sigma_1/\sqrt{n_1}}{\sigma_2/\sqrt{n_2}}$ rather than of $\dfrac{s_1/\sqrt{n_1}}{s_2/\sqrt{n_2}}$?