It’s looking to me like if your CFO were to apply in GA, then once he has the energetic permit, your experience clock would start then. It reads if you ask me like when you did the ongoing work he needed to have an active license, not when you apply just. And it could be active in any state. But calling and asking is always the best way.
Example (4). H, a person, so until April 15th did not enjoy planning his taxation statements and procrastinated in doing. April 15th On, H gathered together his tax records and materials hurriedly, prepared a return, and mailed it before midnight. The return contained numerous errors, some of which were in H’s favour and some which weren’t.
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Facts and circumstances; minimum and requirements. All facts and circumstances considered. The advice must depend on all pertinent facts and circumstances and the law as it pertains to those circumstances and facts. For instance, the advice must look at the taxpayer’s purposes (and the relative weight of such purposes) for getting into a transaction and for structuring a transaction in a specific manner.
No unreasonable assumptions. The advice should not be predicated on unreasonable factual or legal assumptions (including assumptions concerning future events) and should never unreasonably rely on the representations, statements, findings, or contracts of the taxpayer or any other person. Reliance on the invalidity of the legislation. A taxpayer might not rely on an impression or advice that a legislation is invalid to determine that the taxpayer acted with acceptable cause and good faith unless the taxpayer sufficiently disclosed, relative to §1. 6662 accuracy-related charges. Advice does not have to maintain any particular form. Underpayments due to reportable transactions.
Special rules for considerable understatement penalty attributable to tax shelter items of corporations. In general; facts and circumstances. The dedication of whether a company acted with reasonable cause and in good beliefs in its treatment of a taxes shelter item (as described in §1.6662-4(g)(3)) is based on all relevant facts and circumstances. Reasonable cause predicated on legal justification. Federal tax law of the taxes shelter item or of the entity, plan, or set up that provided rise to the item. Thus, a taxpayer’s perception (whether independently formed or based on the advice of others) regarding the merits of the taxpayer’s underlying position is a legal justification. Minimum requirements not dispositive.
Satisfaction of the minimum requirements of paragraph (f)(2) of this section can be an important factor to be looked at in determining whether a corporate and business taxpayer acted with acceptable cause and in good trust, but is not dispositive necessarily. Transactions between people described in section 482 and net section 482 transfer price adjustments.