In a prior year, Bradley Corp. took a very aggressive tax position on its tax return that the predominance of the evidence indicated Bradley would be unable to benefit from if detected under review by the taxing jurisdiction. In the current year, the taxing authorities discovered the tax position and reversed the deduction that Bradley had taken. Bradley was required to pay the tax liability associated with the reversal of the tax item. Rather than pursue a settlement with the revenue agent, Bradley has elected to appeal the issue to Tax Court. Is the issue “effectively settled” under Topic 740?
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