109. Taxpayer A and the IRS are locked in intense litigation over A's income tax liability for the year 2016. The case is on its way to the U.S. Supreme Court. There is a split of opinions between the various Circuit Courts regarding the point of law around which this litigation revolves. The attorney for the government has considerable doubt about A's liability for the tax because of the split of authorities and the IRS believes that a Supreme Court ruling contrary to its position is probable. A, who is equally unsettled about the pending litigation, comes to the government and makes an offer in compromise to settle the dispute by paying 50% of the assessed tax. Nevertheless, the government is prohibited by law from accepting such an offer in compromise. a. True b. False 110. Taxpayer J substantially understated his income for the tax year 2015 but correctly stated his deductions. For the year 2014, J substantially overstated his deductions but correctly stated his income. The three year statute of limitations period has run as to both returns. However, the IRS is asserting that the 6 year limitations "extension is applicable to both the 2015 understatement of income and the 2014 overstatement of deductions. The IRS will prevail as to both years on this extended limitations theory. a. True b. False 69. A nonacquiescence by the IRS is meaningless because the IRS must abide by the adverse court ruling. a. True b. False 70. The IRS disclaims any responsibility for taxpayers' reliance on IRS publications (such as Publication 17). a. True b. False 71. Judicial decisions are a primary source of law. a. True b. False 72. The three trial courts in which a federal tax case may be brought are the U.S. Tax Court, the U.S. District Court, and the U.S. Court of Federal Claims. a. True b. False