If you are a taxpayer in an audit dispute who has exhausted all your administrative remedies, and are in possession of a 90 day letter (a statutory notice of deficiency), and you know of only three court cases ruling on your tax position, and they are from the Ninth Circuit Court of Appeals in your favor, a Tax Court ruling from Pennsylvania going against your position, and a Fourth Circuit Court of Appeals ruling going against your position. Where would you file a case if you live in Maryland and where would you file if you live in Pennsylvania? Assume you have money to pay the taxes assessed, and can file a refund claim, choose the best trial court(s).

Choose between U.S. District Courts, U.S Court of Federal Claims, or the U.S Tax Court