Trial Courts

Review each situation and complete the table, assuming your client has been unable to resolve outstanding issues with the IRS and is now headed to court. List the recommended trial court and reasoning for your recommendation.

Situation	Recommended Trial Court	Reasoning
Your client lives in the 5th circuit. The 5th Circuit Court of Appeals has ruled against the taxpayers position in previous cases.
Your client lives in the 5th circuit. The 9th Circuit Court of Appeals has ruled against the taxpayers position in previous cases.
In addition to the disputed tax position, the taxpayer also has 2 other aggressive positions taken on the return that were not flagged by the IRS.
The disputed liability is $32,000.
The taxpayer is arguing for innocent spouse relief, claiming that she had no knowledge of her husbands illegal activity and underreporting of income. She left him and divorce proceedings are underway.