Kanter: The Third Shoe Drops

Practical and Practice issues for Professionals who practice in the area of taxation. Moral, social and economic issues relating to taxes, including international issues, the U.S. Internal Revenue Code, state tax issues, etc. Not for "tax protestor" issues, which should be posted in the "tax protestor" forum above. The advice or opinion given herein should not be relied on for any purpose whatsoever. Also examines cookie-cutter deals that have no economic substance but exist only to generate losses, as marketed by everybody from solo practitioner tax lawyers to the major accounting firms.
Dr. Caligari
J.D., Miskatonic University School of Crickets
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Joined: Fri Jul 25, 2003 10:02 pm
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Kanter: The Third Shoe Drops

Post by Dr. Caligari »

After the Supreme Court's Kanter decision, which overturned the Tax Court's shameful process of concealing the decisions of Special Trial Judges, the case went back to the Tax Court which again ruled against the taxpayers despite the Special Trial Judge's (now revealed) findings that there had been no fraud. The three taxpayers involved in that case pursued appeals to three different Circuits. Previously, the IRS lost in the Fifth and Eleventh Circuits; the Seventh Circuit, hearing the appeal of the third taxpayer, has now ruled against the IRS as well.

A link to the decision is here: http://taxprof.typepad.com/taxprof_blog ... -cir-.html
Dr. Caligari
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