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Please provide recommendations for a large company (not individuals) to mitigate the risk of losing a challenge by the IRS, declaring that it does not

Please provide recommendations for a large company (not individuals) to mitigate the risk of losing a challenge by the IRS, declaring that it does not qualify for tax-free treatment. (For ex, hiring a strong team of lawyers).

Scenario: taxes, fines, and interest assessed following an IRS legal challenge that is unsuccessful and takes years to resolve. As a result, the maximum amount of taxes, fines, and interest is imposed.

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