The succession of regulations involving repairs from 20061 through 2008 and 2011, all of which were withdrawn, to the final regulations issued in 2013,2 emphasized, to varying degrees, that IRS was favorably inclined toward a “safe harbor” for small taxpayers which was sometimes expressed in terms of a “qualified taxpayer.” The Preamble to the final regulations in the “Explanation of Provisions” referred to a “safe harbor” for small taxpayers.3



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