Monte A. Jackel (PricewaterhouseCoopers, Washington, D.C.), Economic Substance Doctrine and Tax-Motivated Investments, 132 Tax Notes 1157 (Sept. 12, 2011):
In this column, Jackel discusses the Tax Court’s recent decision in Superior Trading [137 T.C. No. 6 (Sept. 1, 2011)] and its significance in the application of the codified economic substance doctrine under § 7701(o).
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