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Houston Has Found Conflicting Authorities That Address a Research Question

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Houston has found conflicting authorities that address a research question for one of his clients.The majority of the authorities provide a favorable answer for his client.Nonetheless,there are several authorities that provide an unfavorable answer.Houston estimates that if the client takes the more favorable position on its tax return that there is approximately a 60 percent chance that the position will be sustained upon audit or judicial proceeding.If the client takes this position on its tax return,will Houston be subject to penalty? Will the client potentially be subject to penalty?


Definitions:

Railroads

A transportation system consisting of a track of rails on which trains travel, used for moving passengers and goods over long distances efficiently.

Dawes Act

A law passed in 1887 that aimed to assimilate Native Americans into US society by allotting individual land parcels to heads of families, stripping away communal tribal land.

Indian Poverty

The state of economic deprivation and lack of access to resources faced by many in India, due to factors such as population density, corruption, and historical inequities.

Tribal Rights

Legal or moral rights recognized for indigenous tribes, including land rights, self-determination, and preservation of culture and language.

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