A New Theory of Code Definitions

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“Manifestly incompatible?”

A new IRS Chief Counsel Advice features a disturbing interpretation of Section 7701’s definitions. Our Federal Tax Group parses out what taxpayers should beware of—or what could possibly be used to their benefit.

  • Applying the abuse of entity regulation
  • Discriminating against taxpayers singled out
  • Statutory construction that doesn’t otherwise provide

Read the full advisory here.