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The IRS recently completed an audit of Shea's tax return and assessed $15.000 additional tax.
She requested an appeals conference but was unable to settle the case at the conference. She is
contemplating which trial court to choose to hear her case. Provide a recommendation based on
the following alternative facts a. Shea resides in the 2 end Circuit, and the 2 nd Circuit has
recently ruled against the position Shea is litigating b. The Federal Circuit Court of Appeals has
recently ruled in favor of Shea's position. c. The iswue being litigated involves a quesbon of fact.
Shea has a very appealing story to tell but little favorable case Law to support her position. d.
The issue being litigated is highly technical, and shea believes strongly in her interpretation of
the law. 6. Shea is a lecal elected otficial and would prefer to minimize any local publicity
regarding the case.

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