Process discovered no additional authority on issue

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Reference no: EM133854836

Question

Your research produces the following material that speaks directly to the issue you are researching for your client who lives in Missouri. Your comprehensive research process discovered no additional authority on the issue. Authority found: A 1980 Tax Court memo decision regarding a taxpayer living in Florida. Your client's facts are just like those in this case. This case held for the IRS and does not support what your taxpayer wants to do. *A 1990 9th Circuit case that holds a position contrary to the Tax Court case in Florida. Your client's facts are just like those in this case. The case held for the taxpayer and supports what your taxpayer wants to do. * A 1991 Revenue Ruling indicating that the Service will acquiesce with the 9th Circuit case going forward. Discuss the relative weight you would give to each of the above three authorities and your reasoning.

Reference no: EM133854836

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