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CHAPTER 5 - CHAPTER 5 DISCUSSION QUESTIONS 1 Answer...

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CHAPTER 5 — DISCUSSION QUESTIONS 1. Answer: Taxpayer appears to be entitled to an LMSB Pre-Filing Agreement. Rev. Proc. 2001-22, IRB 2001-9. Notwithstanding, if the LMSB Industry Director refuses the request, there is no right to appeal. However, if the taxpayer is audited, there may be an opportunity to utilize an advanced resolution procedure and, in any event, there is always the right to subsequently appeal IRS audit adjustments, if any. 2. Answer: Because the IRS examiners are bound to follow revenue rulings, the team manager does not have the authority to settle this issue. Therefore, the taxpayer appears to meet the requirements for the “Early Referral Program to the Appeals Office. An Appeals Officer has “hazards of litigation authority to settle a legal issue contrary to the published position of the IRS. 3. Answer: The authors are hopeful that this problem will prompt spirited discussion among the students. In the course of this discussion, the teacher may explain that the following arrangement
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