You are still thinking
>>NO importance should be given to ANY other court cases<<
You are still thinking like an IRS employee. (Note to Black Bart: that's not an insult. IRS examiners have an important job to do.) It is true that the IRS can sometimes be cranky about losing a case--"We don't care what the stupid judge said, we aren't going to do it that way." An employee has to follow the official interpretation, but that doesn't mean it is any more valid from the taxpayer's point of view.
Of course, every case has unique facts and circumstances. Some court rulings are much narrower than others, perhaps only applying to a certain class of taxpayer or a particular region of the county. That shouldn't stop you from using favorable rulings to model new tax positions.
>>NO importance should be given to ANY other court cases<<
You are still thinking like an IRS employee. (Note to Black Bart: that's not an insult. IRS examiners have an important job to do.) It is true that the IRS can sometimes be cranky about losing a case--"We don't care what the stupid judge said, we aren't going to do it that way." An employee has to follow the official interpretation, but that doesn't mean it is any more valid from the taxpayer's point of view.
Of course, every case has unique facts and circumstances. Some court rulings are much narrower than others, perhaps only applying to a certain class of taxpayer or a particular region of the county. That shouldn't stop you from using favorable rulings to model new tax positions.
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