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Explain the importance of IRS Code Sections 162(a)(1) and 162(a)(2). A taxpayer has a tax issue in which the only authorities are a private letter

Explain the importance of IRS Code Sections 162(a)(1) and 162(a)(2).

A taxpayer has a tax issue in which the only authorities are a private letter ruling that favors the taxpayer's position and a Tax Court decision that opposes the taxpayer's position. What advice would you provide the taxpayer?

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