Chapter 12 - Chapter 12 The Appeals Office 1 Answer...

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Chapter 12 The Appeals Office 1. Answer: Adoption of the equitable estoppel theory results in a negative answer. The more aggressive approach illustrated in the Uinta Livestock decision would allow for the filing of a claim for refund. 2 Answer: The authors believe that the ethical and moral considerations resulting from a breach of a Form 870-AD may be more significant than the legal ramifications in the decisions of most practitioners. 3 (A) Answer: It is the authors’ opinion that the last thing you take to the Appeals conference is your client. Generally, a taxpayer is unable to objectively and unemotionally consider the facts and issues. (B) Answer: An analysis of comparable activities in the area, national statistics or other data should be available so that the practitioner can present sufficient third-party documents to sustain the proffered position. If Leroy’s testimony is an absolute necessity, then submit his affidavit under penalty of perjury.
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Chapter 12 - Chapter 12 The Appeals Office 1 Answer...

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