John E. Bragonje (BYU Class of 2005) has published The Rise and Fall of the Check-the-Box Regime: A Solution to Recent Private Letter Rulings’ Troubling Use of the De Facto Corporation Doctrine, also available on the Tax Analysts web site as Doc 2005-9245, 2005 TNT 87-45. The article examines relief for administrative corporate revocations under the check-the-box regs and argues that the IRS has based relief on an unworkable doctrine that will cause disparate treatment according to the corporation’s home state.
Bragonje on The Rise and Fall of the Check-the-Box Regime
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