The IRS recently assessed a $290,800 income tax deficiency on CMP Corporation. The deficiency is attributable to a complicated accounting issue involving CMP’s in-vestment in a controlled foreign corporation. CMP plans to contest the deficiency in court. CMP is located in the Third Circuit. Neither the local district court, the Tax Court, nor the Third Circuit Court of Appeals has considered the accounting issue. The Court of Federal Claims and the Eighth Circuit Court of Appeals have decided the issue in favor of the government. However, the Ninth and Tenth Circuit Courts of Appeals have decided the identical issue in favor of the taxpayer. Discuss CMP’s litigation strategy in selecting a trial court.