For researchers as well as for policy makers, it is imperative to identify and evaluate key factors in the competitive landscape of today world of higher education in order to develop effective tactics and resources for human capital development, attraction, sustention
, and global mobility.
Assuming that the Tax Court's sustention
of the penalty rested on the sufficiency of the evidence regarding the taxpayer's profit motive, the court observed that the evidence went both ways.
rate has also remained stable at approximately 30 percent of proposed deficiencies.
Finally, he briefly discussed several issues, including joint meetings between Appeals and Examination personnel, the sustention
rate in Appeals, process reviews, the role of Team Chiefs, and the importance of taxpayer involvement in the audit planning process.
Indeed, CEP taxpayers frequently voice concern that the Case Manager declines to become involved in technical issues and, as a result, the elimination of their experience and expertise contributes to the low sustention