John is a resident of Minnesota. Her 2015 federal income tax return is currently under audit. John and the Internal Revenue Service Agent assigned to his case have resolved all issues in his case except one. John's accountant has only discovered one case where the unresolved issue has been litigated and in that case, the Eighth Circuit Court of Appeals rendered a decision favorable to John's’s position. If John and the IRS Agent cannot resolve this issue, He is considering filing a petition in Tax Court to resolve it.
a. If John filed a petition in tax court, is the tax court obligated to follow the decision of the Eighth Circuit Court of Appeals? Why or why not? Please explain.
b. Would your answer above change if John lived in Wisconsin? Please explain