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:

Greater Expertise

A higher level of knowledge, skill, or proficiency in a particular area or field.

Attractive Person

Refers to an individual who is found to be pleasing or appealing to the senses of others, often influenced by both physical traits and personality.

Expertise

The extensive knowledge or skill in a specific field or area, often acquired through experience or education.

Persuasive

Having the power to convince or influence someone to do or believe something through reasoning or the use of emotion.