Implications of Canal Corp. v. Comm'r for U.S. Taxpayers and Their Advisors

Canal Corp. v. Comm'r, 2010 U.S. Tax Ct. LEXIS 25 (T.C. Aug. 5, 2010), has serious implications for U.S. taxpayers and their advisors, especially regarding the issuance of tax opinions requiring a high degree of certainty. Fundamental points of the case as to advisor independence and economic substance...