21. LO.1 A taxpayer living in the following states would appeal a decision of the U.S
District Court to which Court of Appeals?
22. LO.1 What determines the appropriate Circuit Court of Appeals for a particular taxpayer?
23. LO.1, 4 In assessing the validity of a prior court decision, discuss the significance of the following on the taxpayer’s issue:
a. The decision was rendered by the U.S. District Court of Wyoming. Taxpayer lives in
b. The decision was rendered by the U.S. Court of Federal Claims. Taxpayer lives in
c. The decision was rendered by the Second Circuit Court of Appeals. Taxpayer lives in
d. The decision was rendered by the U.S. Supreme Court.
e. The decision was rendered by the U.S. Tax Court. The IRS has acquiesced in the result.
f. Same as (e), except that the IRS has nonacquiesced in the result.
2-38 PART 1 Introduction and Basic Tax Model
24. LO.2 Is there an automatic right to appeal to the U.S. Supreme Court? If so, what is the process?
25. LO.2 Interpret each of the following citations:
a. 14 T.C. 74 (1950).
b. 592 F.2d 1251 (CA–5, 1979).
c. 95–1 USTC ¶50,104 (CA–6, 1995).
d. 75 AFTR 2d 95–110 (CA–6, 1995).
e. 223 F.Supp. 663 (W.D. Tex., 1963).