tag:blogger.com,1999:blog-15517294.post3265933795842528183..comments2024-03-02T02:56:02.147-05:00Comments on RUBIN ON TAX: IRS CAN ACT INCONSISTENT WITH FIELD SERVICE ADVICECharles (Chuck) Rubinhttp://www.blogger.com/profile/07227879267908481649noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-15517294.post-85867818963643002322007-12-13T18:38:00.000-05:002007-12-13T18:38:00.000-05:00Let me see if I understand: IBM cries foul in 1965...Let me see if I understand: IBM cries foul in 1965 when the IRS, confronted with the same set of facts, gives out two different PLR's; one favorable to IBM's competitor, one detrimental to IBM. When the IRS Auditor on the IBM case requested an FSA, the Chief Counsel changes it's position. <BR/><BR/>If that is the case, it seems to me the FSA was is a moot point. It is likely the taxpayer was trying to bind the IRS to the FSA in a desparate attempt to get fair treatment. <BR/><BR/>The important issue is a prior bad act by the IRS in issuing contradictory PLR's for taxpayers with identical facts. In the name of all that is fair, how can that circumstance be allowed to stand? It's as if the IRS can't be bothered with the bothersome task of applying the U.S. code consistently and the court is agreeing!<BR/><BR/>What would you do if this was your client?Muddy Mohttps://www.blogger.com/profile/08322169818122147551noreply@blogger.com