The Tax Court takes on the Fourth Circuit’s version of the sham transaction doctrine. Our Federal Tax Group considers the implications going forward.
- The Tax Court said no
- The peculiar things about the opinion
- The takeaway
The Tax Court takes on the Fourth Circuit’s version of the sham transaction doctrine. Our Federal Tax Group considers the implications going forward.
Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.