A taxpayer lives in michigan in a controversy with

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2-17. A taxpayer lives in Michigan. In a controversy with the IRS, the taxpayer loses at the trial court level. Describe the appeal procedure under the following different assumptions: a. The trial court was the Small Cases Division of the U.S. Tax Court. b. The trial court was the U.S. Tax Court. c. The trial court was a U.S. District Court. d. The trial court was the U.S. Court of Federal Claims.
Answer: See Exhibit 2.4, Exhibit 2.5, and Concept Summary 2.1. 1
a. There is no appeal by either the taxpayer or the IRS from a decision of the Small Cases Division of the U.S. Tax Court. b. The first appeal would be to the Sixth Circuit Court of Appeals. Further appeal would be to the U.S. Supreme Court. c. Same as b. above. d. The appeal would be to the Federal Circuit Court of Appeals and then to the U.S. Supreme Court. Concept Summary 2.1: Federal Judicial System: Trial Courts Issue U.S. Tax Court U.S. District Court U.S. Court of Federal Claims Number of judges per court 19 * Varies 16 Payment of deficiency before trial No Yes Yes Jury trial available No Yes No 2
Issue U.S. Tax Court U.S. District Court U.S. Court of Federal Claims Types of disputes Tax cases only Most criminal and civil issues Claims against the United States Jurisdiction Nationwide Location of taxpayer Nationwide IRS acquiescence policy Yes Yes Yes Appeal route U.S. Court of Appeals U.S. Court of Appeals U.S. Court of Appeals for the Federal Circuit 2-22. What precedents must each of these courts follow? Answer:
2-23. What determines the appropriate Circuit Court of Appeals for a particular taxpayer?
2-24. In assessing the validity of a prior court decision, discuss the significance of the following on the taxpayer's issue:

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