Your client was notified by the IRS that he owes $50,000 in back taxes. In an effort to resolve the dispute you helped him go through the IRS appeals process .... Unfortunately, you were not successful. Thus, you are now prepared to go to court and you have two options (1) TAX COURT (2) DISTRICT COURT. If you were to write a letter to your client, what advantages and disadvantages of each of these options would you list?