In this week’s Tax Geek Tuesday, we’ve been handed a case out of the Tax Court that serves up a veritable smorgasbord of statute, taking us through Sections 351, 1361, 1362, 368, 197, 167, 1239 and ...
The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, 1 which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5. Under these rules, transaction ...
The IRS has been developing policies to attack a variety of tax shelters including the contingent liability shelter, in which a high-basis asset is transferred to a new corporation in exchange for ...
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