When tax returns are filed, it is highly certain that some positions taken would be sustained
upon examination by the taxing
authorities, while others are subject to uncertainty about the merits of the position taken or the amount of the position that would be ultimately sustained.
To the extent called to the attention of an expert witness
upon cross-
examination or relied
upon by the expert witness in direct
examination, statements contained in published treatises, periodicals, or pamphlets on a subject of history, medicine, or other science or art, established a reliable
authority by the testimony or admission of the witness or by other expert testimony or by judicial notice.