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Caplin & Drysdale: LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties

By Mark D. Allison , Christopher S. Rizek and Charles M. Ruchelman Waiting for Guidance As most tax practitioners are aware, the Health Care and Education Reconciliation Act of 2010 added new section 7701(o) of the Internal Revenue Code (the "Code"). This provision codified the judicial doctrine...