Section 10 of House Report 110-314 on HR 1908 Patent ...
`(A) the term `tax planning method' means a plan, strategy, technique, or scheme that is designed to reduce, minimize, or defer, or has, when implemented, the effect of reducing, minimizing, or deferring, a taxpayer's tax liability, but does not include the use of tax preparation software or other tools used solely to perform or model ... ................
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