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:

Share Authority

The distribution of power and responsibilities among various governing bodies or officials.

Privileges and Immunities

The rights and protections granted to citizens of the U.S. by the Constitution, ensuring equality under the law.

Home Rule

The power granted to local governments to govern themselves with minimal or no interference from the national government.

Dual Federalism

A concept of federalism in which federal and state governments have clearly defined, separate spheres of authority and responsibility.