Accuracy-Related Penalties in a Disguised Sale Transaction - Canal Corp.

In Canal Corp. v Comm'r, 135 T.C. No. 9 (Aug 5, 2010) , Chesapeake (the former name of Canal Corp.) wanted to exit the tissue paper industry. For a variety of reasons, Chesapeake decided upon a leveraged partnership structure in which WISCO (Chesapeake's subsidiary), and then Georgia Pacific...