What is the difference between open and closed facts how is


1. Jorge is puzzled that the IRS and his CPA could legitimately reach different conclusions on a tax issue. Why does this happen?

2. What is the difference between open and closed facts? How is this distinction important in conducting tax research?

3. In writing a research memo, what types of facts should be included in the memo?

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Taxation: What is the difference between open and closed facts how is
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