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An advocate may be defined as: 1 One that pleads the cause of another; specifically one that pleads the cause of another before a tribunal or judicial court or 2 One that defends or maintains a cause or proposal Note the differences between the expert and the advocate The definitions alone represent a stark contrast between them Experts are masters in a field Advocates plead or maintain a cause These are two significantly different professions, and in tax matters experts and advocates must remain at a distance The process must demand this, lest the credibility of one suffer greatly Both taxpayers and the IRS have a long way to go to improve on this aspect of the process An advocate may argue; the expert should explain An advocate may defend; the expert should document An advocate may strategize; the expert should outline The differences are significant and compelling The interesting thing to me is that the IRS is not an advocate and doesn t employ them during the audit Audit team members, including valuation specialists, may advocate for the correctness of their conclusions, but not for another goal, such as more tax for the treasury The taxpayer, however, may advocate for his or her best tax position and the best tax outcome consistent with the law The taxpayer may legitimately advocate for the minimum tax possible given the law and facts at issue, while the IRS may not advocate for the converse (the highest possible tax) This is a fundamental policy of tax administration, well documented in the Internal Revenue Manual



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Firewalls U Personalour section on remote attacks, we strongly recommend purchasing one of the To top off

brary that handles many of the TCP/IP issues exploited by these attacks Win 98 users do not need to apply this patch, unless they are North American users wanting to upgrade the default 40-bit encryption that comes with Win 98 to the stronger 128-bit version The Win 95 DUN 13 patch can be found at http://wwwmicrosoftcom/windows95/downloads/ Even with the DUN 13 patch installed, we would advise strongly against deploying any Win 9x system directly on the Internet (that is, without an intervening firewall or other security device)





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However, when I say that the taxpayer may legitimately advocate for the minimum tax possible, given the law and facts at issue, this privilege does not extend to the taxpayer s expert There s the rub! The expert must remain in the role of a subject master This pertains to both the expert representing the taxpayer and the expert representing the IRS This is the single most important fundamental concept to understand And beyond mere understanding, you must ensure that the experts from both parties also understand and abide by these principles Once it is assured that they do, the other representatives can do their jobs and facilitate the audit process through an accurate and satisfying conclusion The experts may well play an important and visible role in this process, but they must remain subject masters and not advocates Then the communications will be materially enhanced, because both parties experts will spend more time discussing professional issues and clarifying professional areas of disagreement, thereby enhancing the resolution process

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It should be fairly well established that users would have to go out of their way to leave a Win 9x system vulnerable to remote compromise; unfortunately, the opposite is true when the attackers have physical access to the system Indeed, given enough time, poor

The business owner has an exceptionally important and interesting role I have already outlined many things you must be aware of and specific actions you may take An audit involving valuation issues may arise as a result of a specific business transaction (purchase, sale, merger, gift, or others) Let me discuss a few additional roles in three different contexts: prior to the transaction, after the transaction, and during the audit

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supervision, and an unobstructed path to a back door, physical access typically results in bodily theft of the system However, in this section, we will assume that wholesale removal of the target is not an option, and highlight some subtle (and not so subtle) techniques for extracting critical information from Win 9x

You will be very busy if you decide to take a more active role in audit-related activities involving valuation-impacted transactions There are several steps the business owner should take

Description: Retrieves the value of the given attribute Returns: The string content of the requested attribute Exceptions: None

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