Tax Law

Recent Posts

Economic Substance Uncertainty in Civil Cases
Posted on 26 Dec 2013 by Jack Townsend

In past entries on this blog, I have expressed concern about deploying the economic substance doctrine in criminal cases. Here is yet another reason for concern. In American International Group v. United States (SDNY 1:09-cv-01871), in a civil tax... Read More

4th Circuit: Denial of Transferee Liability for Intermediary Transaction Tax Shelter Affirmed
Posted on 1 Jun 2012 by Asbury Law Firm

The Fourth Circuit Court of Appeals affirmed the Tax Court's decision in favor of four taxpayers who were alleged to have participated in what the IRS describes as an Intermediary Transaction tax shelter. The majority opinion, authored by Circuit... Read More

Second Circuit Declines Altria's Invitiation to Sustain a BS Tax Shelter
Posted on 4 Oct 2011 by Jack Townsend

The Second Circuit recently rejected another hokey tax shelter in Altria Group, Incorporated v. United States , ___ F.3d ___, 2011 U.S. App. LEXIS 19644 (2d Cir. 2011), here . I have previously blogged on the trial level results in the following blogs... Read More

Courts Reject More BS Tax Shelters
Posted on 7 Oct 2011 by Jack Townsend

DOJ Tax is touting the stunning phenomenon of three major victories in BS tax shelters all in a single day. See Press Release, Justice Department Prevails in Three Tax Shelter Cases on Same Day (10/4/11), here (with links to the pdf files for the opinions... Read More

4th Circuit: Denial of Transferee Liability for Intermediary Transaction Tax Shelter Affirmed
Posted on 1 Jun 2012 by Asbury Law Firm

The Fourth Circuit Court of Appeals affirmed the Tax Court's decision in favor of four taxpayers who were alleged to have participated in what the IRS describes as an Intermediary Transaction tax shelter. The majority opinion, authored by Circuit... Read More