Assume that the only precedents relating to a particular issue are as follows:
Tax Court-decided for the taxpayer
Eighth Circuit Court of Appeals-decided for the taxpayer (affirming the Tax Court)
U.S. District Court for Eastern Louisiana-decided for the taxpayer
Fifth Circuit Court of Appeals-decided for the government (reversing the U.S. District Court of Eastern Louisiana)
a. Discuss the precedential value of the foregoing decisions for your client, who is a California resident
b. If your client, a Texas resident litigates in the Tax Court, how will the court rule? Explain.