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Jackel: Regulatory Antiabuse Rules and the Supreme Court

Tax Analysts 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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