Aaron retains you to represent him with respect to the notice of deficiency. He tells you that, if he is called in any civil trial, he will testify that he believed at the time that the checks he converted to his personal use had been included in the shareholder accounts as a loan to him. He now understands that they weren$$t$,$ however, and he acknowledges that the unreported income amounts stated in the notice of deficiency are correct. He also will testify that he cooperated with all IRS requests for information and that he made all relevant information available to his clerical staffers, who prepared records for Charles to use in preparing the individual and corporate tax returns. Evaluate the issues and Aaron$$s prospects for success in contesting the determinations in the notice of deficiency. Identify any factual ambiguities and describe their potential significance.