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.

---

Definitions:

Urinary Bladder

A hollow muscular organ that stores urine from the kidneys before disposal by urination.

Urogenital Sinus

An embryonic structure that, in humans, develops into parts of the urinary and reproductive systems.

Renal Capsule

A tough fibrous layer surrounding the kidney, providing protection and maintaining its shape.

Adipose Capsule

A layer of fat surrounding certain organs, such as the kidneys, providing cushioning and protection.