Greene is an individual taxpayer residing in Colorado (the Tenth Circuit). She has a disagreement with the IRS on a transaction. Her former accountant told her that she has "less than a 50/50 chance of winning." However, she was recently told of one case with similar facts that was decided in a way that would favor Greene. The U.S. Circuit Court of Appeals for the Fifth Circuit decided that case. If Greene takes her case to the U.S. Tax Court, should she feel confident of prevailing? Explain.

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The Answer of Greene is an individual taxpayer residing in Colorado (the Tenth Circuit). She has a disagreement with the IRS on a transaction. Her former accountant told her that she has "less than a 50/50 chance of winning." However, she was recently told of one case with similar facts that was decided in a way that would favor Greene. The U.S. Circuit Court of Appeals for the Fifth Circuit decided that case. If Greene takes her case to the U.S. Tax Court, should she feel confident of prevailing? Explain.

Greene Is an Individual Taxpayer Residing in Colorado (The Tenth