Tax Court Disallows $14M Loss and Sustains Gross Valuation Penalty in a...
In The Markell Company, Inc. v. Commissioner, T.C. Memo. 2014-86 (May 13, 2014), Judge Holmes disallowed a $14 million capital loss in a Son-of-BOSS [Bond and Option Sales Strategy] (“SOB”)-type...
View ArticleFifth Circuit Holds Interposition of S Corp. Does Not Nullify § 464 Active...
In Burnett Ranches, Limited v. United States, No. 13-10403 (5th Cir. May 22, 2014), the United States appealed the district court’s judgment to reject the government’s attempt to tax Burnett Ranches as...
View ArticleDismantling a Partnership: The IRS’s Toolbox
Today’s guest blogger is Brett Bloom, an associate in KPMG LLP’s international tax group. Prior to joining KPMG, he attended Georgetown University Law Center, where he received his LL.M. in taxation...
View Article
More Pages to Explore .....
