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PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b), THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 201340 UNITED STATES TAX COURT GEORGE RUSSELL RIFF, JR., AND
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Summary opinion 201340 is a form used by taxpayers to provide a brief explanation or summary of their tax position.
Taxpayers who have taken a positions on their tax return that may be considered aggressive or uncertain are required to file summary opinion 201340.
Summary opinion 201340 must be completed by providing a concise explanation of the specific tax position taken on the tax return, including relevant facts and legal arguments.
The purpose of summary opinion 201340 is to provide transparency to tax authorities regarding potentially aggressive or uncertain tax positions taken by taxpayers.
On summary opinion 201340, taxpayers must report the specific tax position taken, relevant factual information, and legal arguments supporting their position.
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