For the Following Taxpayers, Please Recommend the Most Advantageous Trial-Level

question 5

Essay

For the following taxpayers, please recommend the most advantageous trial-level court(s)to litigate a tax issue with the IRS.
a. Joe is litigating a tax issue with the IRS that is considered a question of fact (i.e., the answers depend on the facts of the case). There is not a lot of authority on point for this case, but Joe has a very appealing story to justify his position that is likely to be viewed sympathetically by his peers.
b. The Circuit Court of Appeals for the Federal Circuit recently issued an opinion that is very favorable to the issue that Jesse plans to litigate with the IRS.
c. The Circuit Court of Appeals for the Federal Circuit recently issued an opinion that is not favorable to the issue that Hank plans to litigate with the IRS.
d. The 7 ^th Circuit (where Elizabeth resides)recently issued an opinion that is very favorable to the issue that Elizabeth plans to litigate with the IRS.

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Definitions:

Journal Entries

The method of recording financial transactions in an accounting system, where each transaction is entered twice to maintain the balance of the accounting equation.

Transactions

The events or interactions between businesses or individuals that have economic substance and can be measured in terms of money.

Trial Balance

A bookkeeping worksheet in which the balances of all ledgers are compiled into debit and credit account column totals that are equal, used to ensure the accounting entries are in balance.

T-Accounts

A visual representation used in accounting to show the debits and credits in separate columns for each account in the general ledger.