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Question: 1. Issue: Restate the primary issue(s) in the problem (you can copy and paste from the facts provided below) and if appropriate, list any additional issue(s) you determined were relevant from your research.

2. Conclusion: Answer the basic issue or issues in concise yet meaningful terms. These should be plain-language statements - not "technical" jargon.

3. Arguments and Authorities: Explain the basis for your conclusions above. Include appropriate technical citations with related analysis (e.g. "IRC §172 provides that a business may carry forward a Net Operating Loss generated before 2018 for twenty years..." or "In Gregory v. Helvering, 293 U.S. 465, the United States Supreme Court held that there must be a valid business purpose....").

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