Monte A. Jackel (PricewaterhouseCoopers, Washington, D.C.) has published Regulatory Antiabuse Rules and U.S. Supreme Court Precedent, 129 Tax Notes 835 (Nov. 15, 2010):
This column examines a recent application by the IRS [ILM 201044003] of a regulatory antiabuse rule that is seemingly contrary to binding U.S. Supreme Court precedent in Moline Properties[, Inc. v. Commissioner, 319 U.S. 436 (1943)].
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