Assume you work for a mid-size accounting firm and your supervisor became aware of the Amundsen case, link below, and asks you to write a short summary .Suggestion: include key facts, position of T/P and IRS, IR Code provisions interpreted and conclusion. Also give your opinion of the value of this decision for the tax accountant practitioner.
Tax court decision can be found at:
https://www.taxnotes.com/research/federal/court-do…