Eleventh Circuit directs Tax Court to develop test for substantial understatement penalty.: An article from: The Tax Adviser
Book Details
PublisherAmerican Institute of CPA's
ISBN / ASINB00096JEDY
ISBN-13978B00096JED9
MarketplaceFrance 🇫🇷
Description
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on May 1, 1996. The length of the article is 1891 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The US Court of Appeals for the 11th Circuit affirmed the Tax Court's ruling in Osteen that the taxpayer's losses were nondeductible because of lack of a profit motive under IRC section 183 but reversed the Tax Court's finding that the taxpayer's position lacked substantial authority. The IRS and the Tax Court had imposed a section 6661 substantial understatement penalty on the taxpayer for failing to demonstrate that there was substantial authority for claiming the deductions. The 11th Circuit directed the Tax Court to establish a workable substantial authority standard for cases such as this.
Citation Details
Title: Eleventh Circuit directs Tax Court to develop test for substantial understatement penalty.
Author: Peter C. Barton
Publication:The Tax Adviser (Magazine/Journal)
Date: May 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n5 Page: 277(3)
Distributed by Thomson Gale
From the supplier: The US Court of Appeals for the 11th Circuit affirmed the Tax Court's ruling in Osteen that the taxpayer's losses were nondeductible because of lack of a profit motive under IRC section 183 but reversed the Tax Court's finding that the taxpayer's position lacked substantial authority. The IRS and the Tax Court had imposed a section 6661 substantial understatement penalty on the taxpayer for failing to demonstrate that there was substantial authority for claiming the deductions. The 11th Circuit directed the Tax Court to establish a workable substantial authority standard for cases such as this.
Citation Details
Title: Eleventh Circuit directs Tax Court to develop test for substantial understatement penalty.
Author: Peter C. Barton
Publication:The Tax Adviser (Magazine/Journal)
Date: May 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n5 Page: 277(3)
Distributed by Thomson Gale
