EFTA Document EFTA01365291

the opinion simply represents counsel's best judgment. and is not binding on the IRS or the courts. In this regard. there are no authorities that deal with situations substantially identical to the Issuer's. and the Issuer could be treated as engaged in the conduct of a trade or business as the result of unanticipated activities, changes in law, contrary conclusions by the IRS or other causes. The IRS periodically issues a priority guidance plan indicating areas in which it intends to issue