Thomas A. Cullinan & Shane A. Lord (both of Sutherland Asbill & Brennan, Atlanta) have published Economic Substance Doctrine: Unconstitutionally Vague?, 130 Tax Notes 700 (Feb. 7, 2011):
Cullinan and Lord discuss the uncertainty regarding when the IRS would apply the codified economic substance doctrine and whether it should be concerned that too much uncertainty is bad tax policy that could render the new doctrine vulnerable to constitutional challenges.
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