In legal terms, an appellee is the party against whom an appeal is filed. This person or entity is usually the one who won at the lower court level but must now defend that ruling in a higher court.
The term 'de novo' denotes starting anew or afresh, suggesting a second trial or review as if the first had never occurred. It is commonly used in legal contexts, particularly concerning appeals and retrials.
A petitioner is the party requesting action in a court. In tax disputes, this role is frequently assumed by the taxpayer appealing an IRS position. However, if the government loses and appeals to a higher court, the IRS then assumes the role of the petitioner.
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