For the Following Taxpayers,please Recommend the Most Advantageous Trial Level

question 59

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 depends 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 7ᵗʰ 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:

Availability Heuristic

An intellectual shortcut based on immediate examples that present themselves in a person's thoughts when assessing a specific area, idea, method, or decision.

Writer

An individual who engages in the act of producing written content, such as books, articles, or other textual materials.

Teacher

An individual who instructs or educates others, typically in an academic setting.

Simple Probability

The likelihood of a single event occurring, calculated by dividing the number of favorable outcomes by the total number of possible outcomes.