in the importance of IRS Code Sections 162(a)(1) and 162(a)(2).   A taxpayer has a tax issue in which the only authorities are a private letter ruling that favors the taxpayer's position and

SWFT Comprehensive Volume 2019
42nd Edition
ISBN:9780357233306
Author:Maloney
Publisher:Maloney
Chapter26: Tax Practice And Ethics
Section: Chapter Questions
Problem 3BCRQ
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Explain the importance of IRS Code Sections 162(a)(1) and 162(a)(2).

 

A taxpayer has a tax issue in which the only authorities are a private letter ruling that favors the taxpayer's position and a Tax Court decision that opposes the taxpayer's position. What advice would you provide the taxpayer?

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