ABC Corporation, a calendar year taxpayer, purchased a business in January 20X1. The tax department wants to authoritatively determine the basis for the acquired assets prior to filing its 20X1 return. What course of action would you advise? What are the appeal rights for your suggested course of action?

2. During an examination, the IRS proposes an adjustment based on a revenue ruling that appears to be squarely on point. However, taxpayer contends that the Revenue Ruling is contrary to established tax law. How can taxpayer expedite resolution of this matter?