Burgess J.W. Raby & William L. Raby have published Costs of Deals That Don’t Get Done, also available on the Tax Analysts web site as Doc 2005-7072, 2005 TNT 66-34. The article discuss cases and rulings (from Portland Furniture Manufacturing Co. v. Commissioner, 30 B.T.A. 878 (1934), through Tech. Adv. Mem. 2005-12-021 (released 3/25/05)) dealing with the tax treatment of costs related to corporate deals such as mergers and acquisitions that are never completed.



