Todd has been working on a tax research question for a client.He knows he will be referring the issue to the client’s CPA andattorney, but he wanted to give the client some general informationabout how the issue could be handled and they wanted to discuss ittogether. Todd has found several private letter rulings, one courtcase, and a revenue ruling, all from 1980 or earlier that arecontrary to what his client is trying to do. He has found threeappeals court rulings more recent than 1980 that somewhat supportwhat his client wants to do. He also found a Temporary Regulationthat is similar to his situation, but not exactly, and providessome support. Finally, Todd found a Technical Advice Memorandumvery similar to his position which supports his position. Whichdocuments should Todd place the greatest reliance on? In general,should Todd tell his client that tax law appears to support or notsupport the client’s position? (3pts)
