{"id":"W2980048346","doi":"10.32721/ctj.2019.67.3.lubetsky","title":"Income Tax Disputes Involving Loss Years: Pitfalls, Foibles, and Possible Reforms","year":2019,"lang":"en","type":"article","venue":"Canadian Tax Journal/Revue fiscale canadienne","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Taxpayer; Statute; Arrears; Appeal; Accounts payable; Economics; Law and economics; Income tax; Tax court; Statutory law; Indirect tax; Law; Debt; Political science; Tax reform; Public economics; Payment; Finance","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":true,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":["metaepi_narrow","insufficient_payload"],"consensus_categories":[],"category_scores_codex":[0.0005292562,0.0002960381,0.0003859025,0.001000768,0.0005613501,0.0008255492,0.0004856962,0.0001828872,0.00144956],"category_scores_gemma":[0.0002321376,0.0002863784,0.0001042523,0.0006770865,0.00008974635,0.0018338,0.0001295445,0.0005618704,0.0003535853],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.000541592,"about_ca_system_score_gemma":0.0002157863,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.4952195,"about_ca_topic_score_gemma":0.9317989,"domain_scores_codex":[0.9979394,0.00001909837,0.0004499173,0.0003911515,0.0001702943,0.001030153],"domain_scores_gemma":[0.9984326,0.00003475956,0.0004169889,0.0003740376,0.0002219405,0.0005196934],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"observational","study_design_gemma":"not_applicable","study_design_scores_codex":[0.00004036392,0.00004734085,0.8426292,0.0007389113,0.0001800035,0.001701743,0.002688092,0.0001497132,0.0002773124,0.07320262,0.06438655,0.01395818],"study_design_scores_gemma":[0.0007195793,0.00003171844,0.1684794,0.0003894499,0.00004181159,0.0002297918,0.0009021068,0.0007021513,0.000009037977,0.0041931,0.8237211,0.000580768],"study_design_candidate":"observational","study_design_consensus":null,"genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.9752856,0.001310133,0.00001597603,0.007263705,0.00130325,0.0002918615,0.00006508775,0.00005465991,0.01440968],"genre_scores_gemma":[0.971731,0.0001041432,0.0001902379,0.001760321,0.001726471,0.000008554937,0.00005230149,0.00006727456,0.02435971],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.7593346,"threshold_uncertainty_score":0.9999588,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.007912163595830931,"score_gpt":0.1777896541881128,"score_spread":0.1698774905922819,"validation_status":"score_only:v0-immature-baseline","note":"Baseline scores from an immature model (maturity gate not passed). Scores rank; they never assert a category."}}