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In undertaking research, you find a revenue ruling that makes clear that your taxpayer cannot take the tax position they want to. You also find

In undertaking research, you find a revenue ruling that makes clear that your taxpayer cannot take the tax position they want to. You also find a case (from a court with no jurisdiction over your taxpayer) that suggests that your taxpayer can take the tax position they want to. Assume that these two sources are the only and best sources relevant to your analysis. How would you decide which source to rely on for a research conclusion?

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