17. Your client is vigorously challenging the IRSs determination of your clients stock cost basis that resulted from its recent stock-for-stock acquisition of another company. Your clients claim is being decided within the IRS internal appeals process, not by a court. The IRS will conclude that either a carryover basis or a market value basis is appropriate.

Your client has agreed to pay you $80,000 if the IRS approves of a market value basis. Otherwise, you receive nothing.

a. Is your fee arrangement a contingent fee?

b. Does it comply with the Code of Conducts Contingent Fees Rule?