Problem: Maxima Corporation was formed in 1980 as a manufacturer of sportswear for men and women. In 2019, the Treasury Department promulgated final regulations interpreting a new law that was part of the new 2018 tax law. Maxima's tax department believes the regulations may cause some negative tax results for Maxima in 2019. Maxima believes the negative effects don't apply to them based on how a particular transaction was structured, but there is doubt. If the income from the transaction were reported in 2019, Maxima's tax liability would significantly increase. Maxima would like to avoid any of the accuracy related from being applicable. What should the company do to mitigate this risk? Will the approach always work?