Law enforcers cannot lull people or businesses into reasonable reliance
only to later attack, citing a regime change.
Taxpayers and their representatives often argue that a failure to timely file a tax or information return or to timely pay any tax owed was due to reasonable reliance
on the advice of a professional tax adviser.
That is, practitioners must base all written advice on reasonable factual and legal assumptions, exercise reasonable reliance
, and consider all relevant facts that the practitioner knows or should know.
Accordingly," held the Court, "the (7-Eleven Franchise Agreement) disclaimer must be given effect, and Plaintiffs cannot successfully allege the element of reasonable reliance
court may use a reasonable reliance
standard to determine whether the
works out the extent and limits of reasonable reliance
on Josephus in the next three chapters.
My argument is that regulatory duties constitute a distinct category of public authority liability, and that the state should not owe a duty of care in the absence of reasonable reliance
on the state activity.
95-600 says that a business owner's classification of a worker as an independent contractor will be considered reasonable if it was made in reasonable reliance
on past IRS audit practice with respect to the business; published rulings or judicial precedent; recognized practice in the business' industry; or IRS technical advice or a letter ruling given to the business.
In addition, courts found that plaintiffs in most cases would have to show the reasonable reliance
of each customer on those alleged misrepresentations.
Under such circumstances, the patient would be entitled to damages for injuries proximately caused by the surgery if the patient could show reasonable reliance
on the misrepresentations made by the physician and the detriment to the patient.
Further, the new rules appear consistent with state law provisions permitting directors to place reasonable reliance
on management representations and expert opinions.
In order to prove fraud or misrepresentation, the claimant must show that there was reasonable reliance
on the statements made.