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Suppose you are researching whether your client's specific facts relating to its initial incorporation qualify for tax deferral under 351. Given what you have read

Suppose you are researching whether your client's specific facts relating to its initial incorporation qualify for tax deferral under 351. Given what you have read about Treasury Regulations, IRS Revenue Rulings, and Revenue Procedures, would you expect relatively more or less guidance relevant for your client's issue from each of these authorities for those topics? Why would you expect that? What other authority would you consult if reading regulations, rulings and procedures did not satisfy you (i.e., if you wanted additional guidance to provide to your client)?

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