Explain the difference between closed$-$fact and open$-$fact situations.

A$.$ In a closed$-$fact situation, the facts have occurred, and the tax advisor's task is to analyze them to determine the appropriate tax treatment. In an open$-$fact situation, the facts have not yet occurred, and the tax advisor's task is to plan them or shape them into a favorable tax result.

B$.$ In a closed$-$fact situation, the facts have not yet occurred, and the tax advisor's task is to plan them or shape them into a favorable tax result In an open$-$fact situation, the facts have occurred, and the tax advisor's task is to analyze them to determine the appropriate tax treatment.

C$.$ In a closed$-$fact situation, the facts have occurred, and the tax advisor's task is to plan or shape the facts into a favorable tax result. In an open$-$fact situation, the facts have not yet occurred and the tax advisor's task is to analyze them to determine the appropriate tax treatment.

D$.$ None of the above