Why do some taxpayers secure an advance ruling for a proposed reorganization$$ transaction?

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Part $1$

A$.$

Without the advance$$ rulings, if the IRS or courts challenge and subsequently redetermine the$$ reorganization, it might have adverse tax consequences for the parties involved in the transaction.

B$.$

Advance rulings generally are requested because of the complexity of the tax law in the realm of reorganizations and because these transactions involve substantial dollar amounts.

C$.$

Advance rulings offer a degree of security and generally can be relied upon by the parties to the reorganization.

D$.$

All of the above.