On which of the following issues will the IRS likely issue a private letter ruling and why? In your answer, assume that no other IRS pronouncement addresses the issue and that pertinent Treasury Regulations are not forthcoming.
a. Whether the taxpayer correctly calculated a capital gain reported on last year’s tax return.
b. The tax consequences of using stock derivatives in a corporate reorganization.
c. Whether a mathematical formula correctly calculates the fair market value of a stock derivative.
d. Whether the cost of an Internet course that purports to improve existing employment skills may be deducted this year as a business expense.