1. List an advantage and a disadvantage of using the U.S. Tax Court as the trial court for Federal tax litigation.

2. 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.