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Roddy was researching an issue and found a favorable tax court decision that addresses his issue. He also determined that the
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Except for Supreme Court cases, whenever the IRS loses, it may issue an acquiescence or nonacquiescence as guidance for how the IRS intends to respond to the loss. An acquiescence indicates that the IRS has decided to "follow" the court's adverse ruling in the future - i.e., the IRS will no longer litigate this issue. A nonacquiescence has the exact opposite implications. A nonacquiescence alerts taxpayers that the IRS plans to continue to litigate this issue. Roddy can still rely on the favourable Tax Court case but should alert his client that the IRS has stated very clearly that it does not agree with the Tax Court opinion and will continue to litigate this issue.

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