In assessing the validity of a court decision, discuss the significance of the following:

a. The decision was rendered by the U.S. District Court of Utah. Taxpayer lives in Utah.

b. The decision was rendered by the U.S. Court of Federal Claims. Taxpayer lives in Utah.

c. The decision was rendered by the Second Circuit Court of Appeals. Taxpayer lives in California.

d. The decision was rendered by the U.S. Supreme Court.

e. The decision was rendered by the U.S. Tax Court. The IRS has acquiesced in the result.

f. Same as (e), except that the IRS has issued a non-acquiescence as to the result.