This advisory discusses how the Tax Court applied the economic substance doctrine in Gerdau MacSteel, Inc., 139 TC No. 5 (August 30, 2012), and denied penalty relief in a liability management company “tax shelter” case because the company’s tax department failed to either obtain an outside opinion or write its own.
The advisory is provided in PDF on the Alston & Bird website:
www.alston.com/advisories/federal-tax-advisory-federal-tax-report-october-2012