Following up on my prior posts:
- Tax Court Upholds $37m Penalty Against TP Who Relied on Tax Opinion Issued by PWC for $800k Flat Fee (Aug. 6, 2010)
- More on Tax Court's Approval of $37m Penalty Because of PWC's 'Tainted' Opinion (Given for $800k Flat Fee) (Aug. 7, 2010)
Sam Young, Court 'Misguided' in Accuracy-Related Penalty Decision, Practitioners Say, 2010 TNT 152-1 (Aug. 9, 2010):
Practitioners contacted by Tax Analysts say they are troubled by the Tax Court's application of the § 6662(b)(2) accuracy-related penalty in its August 4 Canal Corp. v. Commissioner ruling and disagreed on the impact the case will have on leveraged partnerships.
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