No notice is good notice no? In plain English they left you hanging. The Notice indicates that their position is that the misc. item. Ded. rule taints the deduction. But.... what if all the items were items that would not be considered misc. item. ded. Like legal fees, commissions, accountings etc. Can you take a filing position? Deduct the items that would not have been considered misc. item. ded. to the Trust or Estate. Disclosure? Form 8275? Don't claim and look for guidance and possibly amend if they change their mind? Go on extension? Pray?
Very truly yours,
ROBERT S. BARNETT
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Praying – new form of tax planning option? With this new tax law praying is going to become more popular J
The approach you are suggesting is reasonable and probably the right theoretical answer but remember the CPA penalty provisions as technically it is not supported yet in the law or IRS releases
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