Tax Law

Recent Posts

A Successful Disguised Sale Challenge - Canal Corp. v. Comm'r
Posted on 1 Feb 2011 by Charles Zubrzycki

A disguised sale may occur when a partner contributes property to a partnership and then immediately receives a cash distribution or other consideration from the partnership. Disguised sales are taxable to the partner as of the date of the contribution... Read More

Accuracy-Related Penalties in a Disguised Sale Transaction - Canal Corp.
Posted on 6 Feb 2011 by Charles Zubrzycki

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... Read More