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The Tax Court departs from its general policy of ruling uniformly acquiescence for all taxpayers where: a The Court of Appeals in the circuit to

The Tax Court departs from its general policy of ruling uniformly acquiescence for all taxpayers where:

a The Court of Appeals in the circuit to which the Tax Court decision would be appealed has ruled differently on the issue
b The U.S. Court of Federal Claims has ruled differently on the issue in the taxpayer's jurisdiction
c The IRS has indicated that it will acquisecence
d A U.S. District Court has ruled differently on the issue in the taxpayer's jurisdiction

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