An International Meeting of the American Accounting Association American Accounting Association 2006 Annual Meeting August 6–9, 2006 Washington, D.C.

Robert E. Blatz Jr.
University of Michigan - Dearborn

Abstract: Taxpayers are permitted to raise tax disputes in several forums, both judicial and administrative. Venue rules play an integral role not only in gaining access to these forums, but also in determining the legal precedents that will be applied by a reviewing official. The interaction of these venue rules and the mobility of the individual taxpayer provide opportunities to “forum shop.” These opportunities, however, are less prevalent for corporate taxpayers due to the obvious difficulty in easily changing the corporation’s “principal office or principal place of business.” This article presents a “one-stop shop” analytical guide to these diverse venue rules, starting with the initial filing of a tax return or refund claim and culminating with the filing of an appeal with a United States Court of Appeals. Particular attention is paid to the choice of law issues that arise from intercircuit conflicts in the United States Courts of Appeals.

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