IRS Releases Tax Shelter Examination Guide

The IRS yesterday released on its web site Examination Guide — Abusive Tax Shelters and Transactions:

This guide was developed to support IRS field personnel in the identification and the consistent development of abusive tax shelter and transaction issues. The guuide covers transactions engaged in by all types of taxpayers, including "listed transactions" (known abusive), identified transactions that have not been listed, and emerging transactions.

Of particular interest is Part II: Judicial Doctrines Used to Combat Abusive Tax Shelters

A. Introduction
B. Judicial Doctrines
C. Case Analysis
- Gregory v. Helvering
- ACM
- SABA
- Winn-Dixie
- C.M. Holdings, Inc
- American Electric Power, Inc
- Rice’s Toyota World
- UPS

For the full table of contents, see here.

About the Author

Paul Caron

Paul Caron was named Duane and Kelly Roberts Dean of Pepperdine University School of Law on June 1, 2017. Dean Caron joined the Pepperdine faculty in 2013 after serving as the Dorothy and Leonard Straus Distinguished Visiting Professor of Law in the spring semesters of 2010 through 2013. He served as Associate Dean for Research and Faculty Development at Pepperdine in 2015-2017. Before coming to Pepperdine, he was Associate Dean of Faculty and Charles Hartsock Professor of Law at the University of Cincinnati College of Law.