For the Following Taxpayers, Please Recommend the Most Advantageous Trial

question 106

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 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:

Liverworts

A group of non-vascular plants belonging to the division Bryophyta, known for their liver-shaped leaves.

Sorus

In ferns, a cluster of spore-producing sporangia.

Sporangia

Structures in fungi, algae, and some plants that produce and contain spores for reproduction.

Homosporous

A term referring to plants that produce only one type of spore, typically leading to the development of a single type of gametophyte.