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Treasury’s Section 482 Regulation Losses

September 16, 2019 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory Tagged With: Altera, Amazon, census, Chernery, Chevron, IRS, Ninth Curcuit, section 482, State Farm, Tax Court, Treasury

About Jasper L. (Jack) Cummings, Jr.

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.

[Read Bio]

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