Tag Archives: CCA

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. [...]Read more