Assume that the only precedents relating to a particular issue are as follows:
Tax Court—decided for the taxpayer
Eighth Circuit Court of Appeals—decided for the taxpayer (affirming the Tax Court)
U.S. District Court for Eastern Louisiana—decided for the taxpayer
Fifth Circuit Court of Appeals—decided for the government (reversing the U.S. District Court of Eastern Louisiana)
a. Discuss the precedential value of the foregoing decisions for your client, who is a California resident.
b. If your client, a Texas resident, litigates in the Tax Court, how will the court rule? Explain.