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- You and your client have been working together on an IRS audit. It has been rather frustrating. The IRS has been really stubborn, and their final answer is they are not going to accept your offer by issuing a 90 Day Letter. You have three options for your client. What are they and what are the advantages and disadvantages of each?Explain why the following statement is not necessarily true: If the IRS disagrees, Ill take my case all the way to the Supreme Court.If a U.S. Tax Court agrees with the taxpayer on appeal that the IRS position was largely unjustified, which of the following is correct? The taxpayer must still pay administrative and litigation costs. The taxpayer may recover administrative but not litigation costs. The taxpayer may recover litigation but not administrative costs. To be eligible to recover some of the administrative and litigation costs, the taxpayer must have tried to resolve the case administratively, including going through the appeals process, and must have given the IRS the information necessary to resolve the case. None of the above.