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:

Mnemonic Devices

Strategies for enhancing memory.

Enhancing Memory

Techniques or practices aimed at improving the ability to store, retain, and recall information.

Overlearning

Continued rehearsal of material after one has first appeared to have mastered it.

Continued Rehearsal

The repetitive practice or review of information or skills to reinforce learning and facilitate memory retention.