James has just been audited by the IRS and, as a result, has been assessed a substantial deficiency (which he has not yet paid) in additional income taxes. In preparing

James has just been audited by the IRS and, as a result, has been assessed a substantial deficiency (which he has not yet paid) in additional income taxes. In preparing his defense, James advances the following possibilities. Are any of them viable? Although a resident of Texas, James plans to sue in a District Court in Oregon that appears to be more favorably inclined toward taxpayers. If (a) is not possible, James plans to take his case to a Texas state court as he is more familiar with the practices there. Yes If he loses at the trial court level, James plans to appeal to either the Federal Circuit or the 11 th Circuit Court of Appeals because he has relatives in both Washington D.C., and Atlanta. Staying with these relatives could save James lodging expense while his appeal is being heard by the court. Even if he does not win at the trial court or appeal court level, James feels certain of success on an appeal to the Supreme Court.

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