Suppose that you research an issue for your client relating to preparing the client’s tax return and you find an appellate court case from another appellate region that supports your client’s position, a Tax Court case that supports the IRS position, and a district court case from another state that also supports the IRS position. a. Discuss how you would assess the relative authoritativeness or each case and its impact on your assessment of your client’s position. b. Suppose that the transaction in question was prospective in nature (i.e., it had not yet occurred). What advice would you give your client relating to how to structure this transaction given the three court cases above?

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An appellate court case from another appellate region that supports the clients position In 2014 the United States Court of Appeals for the Eleventh Circuit became the third federal appellate court to View the full answer