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:

Conditioned Stimulus

A previously neutral stimulus that, after association with an unconditioned stimulus, elicits a conditioned response.

Unconditioned Response

The automatic or natural reaction to a stimulus in classical conditioning, which occurs without the necessity for prior learning.

Conditioned Response

A learned response to a previously neutral stimulus after it has been repeatedly associated with an unconditioned stimulus.

Behavioral Perspective

An approach in psychology that focuses on observable behaviors, emphasizing the effects of learning and environment on actions.