I just rendered an opinion regarding your opinion on backdating estimated payment dates and the possible risk for doing so. The risk may be minimal or non-existent but a possible risk nevertheless. There is no authoritative position on this.
On the other hand, since you were an ex-IRS employee, do you have any authoritative citation reporting your position? If so, it would take precedent to my position. I do believe though this is a gray area that is open to interpretation, at best.
@guywong
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