Todd has been working on a tax research question for a client.

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 and attorney, but he wanted to give the client some general information about how the issue could be handled and they wanted to discuss it together. Todd has found several private letter rulings, one court case, and a revenue ruling, all from 1980 or earlier that are contrary to what his client is trying to do. He has found three appeals court rulings more recent than 1980 that somewhat support what his client wants to do. He also found a Temporary Regulation that is similar to his situation, but not exactly, and provides some support. Finally, Todd found a Technical Advice Memorandum very similar to his position which supports his position. Which documents should Todd place the greatest reliance on? In general, should Todd tell his client that tax law appears to support or not support the client’s position? 

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