The IRS recently completed an audit of Sheas tax return and assessed $15,000 additional tax. Shea 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: No Citations, just a written response- do not copy previous CHEGG answers, those are not correct for this question. TY

1.Shea resides in the 2nd Circuit, and the 2nd Circuit has recently ruled against the position Shea is litigating.

2.The Federal Circuit Court of Appeals has recently ruled in favor of Sheas position.

3.The issue being litigated involves a question of fact. Shea has a very appealing story to tell but little favorable case law to support her position.

4.The issue being litigated is highly technical, and Shea believes strongly in her interpretation of the law.