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Attached is an article I had published in Tax Notes on September 18, 2017.  As of this posting, on October 16, the case is still pending appeal to the 9th Circuit.  A date has not yet been set for oral argument.
156tn1575_attribution.pdf
File Size: 944 kb
File Type: pdf
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And of course eventually the 9th Circuit did affirm, setting exactly the shaky precedent we had predicted.  Linked below it an article from Tax Notes reporting the decision and quoting your correspondent at length.
parillo__03-18-2019_.pdf
File Size: 739 kb
File Type: pdf
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The paralegal consulting services described on this site are offered only to lawyers.
Russ is not maintaining an active license to practice law.
He is not licensed in Arizona, and he does not offer legal services in Arizona.

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