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reasonable reliance

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reasonable reliance n. particularly in contracts, what a prudent person would believe and act upon if told something by another. Typically, a person is promised a profit or other benefit, and in reliance takes steps in reliance on the promise, only to find the statements or promises were not true or exaggerated. The one who relied can recover damages for the costs of his/her actions or demand performance if the reliance was "reasonable." If the promisor says he "owned the Brooklyn Bridge," reliance on that statement is not reasonable. In a complaint the language would read something like: "in reasonable reliance on defendant's statement (or promise), plaintiff did the following...." (See: contract)


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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.
6664-4(c) facts-and-circumstances standard regarding a taxpayer's reasonable reliance in good faith on advice from a tax professional.
Current regulations provide that reasonable reliance on a qualified opinion from a tax adviser is a helpful, but not decisive, factor in establishing that a taxpayer acted with reasonable cause and in good faith.
 
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