For the Following Taxpayers, Please Recommend the Most Advantageous Trial

question 79

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 tojustify 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 theissue that Elizabeth plans to litigate with the IRS.

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Definitions:

Analytical Intelligence

Part of Sternberg's Triarchic Theory of Intelligence, it involves the ability to analyze, evaluate, judge, compare, and contrast.

Creative Intelligence

The capacity to solve novel problems and come up with original and appropriate solutions.

Experiential Intelligence

The ability to use one's own experiences effectively for learning and problem-solving, often related to practical intelligence.

Componential Intelligence

One aspect of triarchic theory of intelligence, focusing on analytical abilities such as problem-solving and logical reasoning.