14. LO.1 Which of the following would be considered advantages of the Small Cases Division of the Tax Court?
a. Appeal to the U.S. Tax Court is possible.
b. A hearing of a deficiency of $65,000 is considered on a timely basis.
c. Taxpayer can handle the litigation without using a lawyer or certified public accountant.
d. Taxpayer can use Small Cases Division decisions for precedential value.
e. The actual hearing is conducted informally.
f. Travel time will probably be reduced.
15. LO.1 List an advantage and a disadvantage of using the U.S. Court of Federal Claims as the trial court for Federal tax litigation.
16. LO.1, 5 Eddy Falls is considering litigating a tax deficiency of approximately $229,030 in the court system. He asks you to provide him with a short description of his alternatives indicating the advantages and disadvantages of each. Prepare your response to
Eddy in the form of a letter. His address is 200 Mesa Drive, Tucson, AZ 85714.
17. LO.1 List an advantage and a disadvantage of using the U.S. Tax Court as the trial court for Federal tax litigation.
18. LO.1 A taxpayer lives in Michigan. In a controversy with the IRS, the taxpayer loses at the trial court level. Describe the appeal procedure for each of the following trial courts:
a. Small Cases Division of the U.S. Tax Court.
b. U.S. Tax Court.
c. U.S. District Court.
d. U.S. Court of Federal Claims.
19. LO.1 What is meant by petitioner?
20. LO.1 An appellate court will often become involved in fact-finding determination.
Discuss the validity of this statement.