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 depend 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.
What will be an ideal response?
(a) U.S. District Court because it is the only court that offers a jury trial. (b) The U.S. Court of Federal Claims because its appellate court is the Circuit Court of Appeals for the Federal Circuit. (c) The U.S. Tax Court or the U.S. District Court because they will not appeal to the Circuit Court of Appeals for the Federal Circuit. (d) The U.S. Tax Court or the U.S. District Court because they will appeal to the 7th Circuit.
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