Which of the Following Statements Is Not True with Respect

Which of the following statements is not true with respect to tax litigation?

A) Of the three types of opinions issued by the Tax Court, a memorandum opinion (in theory not always in practice) applies well established principles of law to facts found by the court.
B) If a taxpayer elects the Tax Court's "small tax procedures" (available for disputes involving $50,000 or less) , a summary opinion, which is not open to appeal is issued by the Tax Court.
C) District courts hear only disputes involving federal tax law.
D) Decisions by a U.S. district court may be appealed to the Court of Appeals having jurisdiction over the district court.