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In the course of researching whether a particular tax position of your tax client satisfies the realistic possibility of success standard, you discover that another taxpayer took the same position on a tax return several years ago and that the return was audited by the IRS. You discover that the IRS agent who conducted the audit was aware of the position and decided the treatment on the return was correct. The revenue agent's report, however, made no mention of the position.
Do you believe the determination by the revenue agent provides sufficient authority for purposes of the realistic possibility of success standard with respect to your client's tax position? Explain why or why not, in light of SSTS No. 1. Assume you adopt that position, what should your tax client do as a result and why?
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Write a two page (double spaced) review of the article you chose. Make sure you submit your assignment in the required format.
The government asked a court to order Apple to create a unique version of iOS that would bypass security protections on the iPhone Lock screen. Apple strongly objects to this order. The government says Apple's objection appears to be based on concern..
BUSINESS INFORMATION SYSTEMS 612 ASSIGNMENT. You are employed as a communications advisor at Telemark, a telemarketing firm with over 1,500 telemarketers. How does Internet telephony work? What type of hardware and software must the company purchase ..
Lee Calan refused to sell the car for $1,095. O'Keefe sued, claiming that the advertisement was an offer that he accepted, creating a binding agreement. Was O'Keefe correct? Explain.
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The activities of the Australian Wheat Board (AWB) were in the news almost every day during the first part of 2006.
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How many pounds of beef and grain should be included in each pound of dog food? What is the cost and vitamin content of the final product
What do you see as the key differences between using social media and traditional media for corporate marketing? What kinds of technologies might be useful in aiding the updating of a marketing plan to include social media and web applications
Explain the multiple aspects of the managerial planning process and the application of various business- and corporate-level strategies.
A. If management uses maximum expected monetary value as the decision criterion, which alternative should it choose?
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