September 16, 2015

IRC Section 269 and when it disallows a net operating loss

With the enactment of IRC Code Section 269, Congress sought to combat certain tax evading strategies involved with the acquisition of a corporation (or its assets). […]
July 28, 2014

What is a tax shelter? What are some examples?

A. Tax Shelters—Generally The Tax Court has consistently disallowed losses, deductions, and credits from transactions it deems to be “tax shelters.” A tax shelter is, among […]
July 28, 2014

How does the IRS attack tax shelters on IRC Section 183

Some people have significant income from more than one source. And some of these people seek to reduce their taxable income by reporting losses from other […]
July 28, 2014

Relationship between Section 183 and other tax doctrines

This is a great question. We consider various alternatives—for example, whether a transaction passes the test under Section 183 but not a related tax doctrine (and […]
July 28, 2014

The difference between tax evasion and tax avoidance

Introduction: An Initial Definition The difference between tax evasion and tax avoidance is an important one because “tax evasion” is criminal, but “tax avoidance” is not. […]
July 28, 2014

What is the Step Transaction Doctrine?

The step transaction doctrine dictates that a series of formally separate steps will be collapsed into one step, with the tax consequences applying to the one […]