If your points are all close to the plane, you have a choice between ordinary least squares (where you see Z as a function of two independent variables X and Y and you minimize the sum of squared vertical distances to the plane), or total least squares (all variables independent, minimize the sum of normal distances). The latter requires a 3x3 SVD. (See http://en.wikipedia.org/wiki/Total_least_squares, unfortunately not the easiest presentation.)
If some of the points are outliers, you will need to resort to robust fitting methods. One of them is RANSAC: choose three points are random, build their plane and compute the sum of distances of all points to the plane, as a measure of fitness. Keep the best result after N drawings.