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Please use this format: Issue Facts Authority Analysis and Discussion Acct 5205 Adv Federal Taxation Tax Research Question Chapter 2 Colleen is in the business

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Issue

Facts

Authority

Analysis and Discussion

Acct 5205 Adv Federal Taxation Tax Research Question Chapter 2 Colleen is in the business of licensing software to customers. Colleen discusses and evaluates the customer's software needs with the customer. The taxpayer advises the customer on the particular software products it licenses. Colleen is paid a flat price for the software license. After the customer licenses the software, Colleen helps to implement the software. Colleen is engaged in the trade or business of licensing software and not engaged in an SSTB in the field of consulting within the meaning of section 199A(d)(2) or paragraphs (b)(1)(vi) and (b)(2)(vii) of this section. $1.199A-5 Specified service trades or businesses and the trade or business of performing services as an employee. (b)(3)(x)Example 10 Acct 5205 Adv Federal Taxation Tax Research Question Chapter 2 Colleen is in the business of licensing software to customers. Colleen discusses and evaluates the customer's software needs with the customer. The taxpayer advises the customer on the particular software products it licenses. Colleen is paid a flat price for the software license. After the customer licenses the software, Colleen helps to implement the software. Colleen is engaged in the trade or business of licensing software and not engaged in an SSTB in the field of consulting within the meaning of section 199A(d)(2) or paragraphs (b)(1)(vi) and (b)(2)(vii) of this section. $1.199A-5 Specified service trades or businesses and the trade or business of performing services as an employee. (b)(3)(x)Example 10

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