Do what Treasury said, not what it says it meant.
Earlier this month, our Federal Tax Group explains why the circuit court affirmed one Tax Court decision and reversed another in the name of consistency – and why it means regulation preambles are more important than ever.
- Affirming in Amazon, reversing in Altera
- Holding the IRS to literal terms of the regulation
- Similarity to the Supreme Court ruling on the census citizenship question
Read the full advisory here.