Present opposition with persuasive argument based on highly relevant cases.
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Can a taxpayer use the reasonable cause and good faith defense to avoid the accuracy-related penalty for an underpayment of tax pursuant to § 6662?
Is an interest in a corporation debt or equity for federal tax purposes?
Is a corporation a controlled foreign corporation or a passive investment foreign company for the purposes of the Internal Revenue Code?
Does a transaction have economic substance for tax purposes?
Is a worker an employee or an independent contractor for tax purposes?
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