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Showing posts with label Listed Transactions. Show all posts
Showing posts with label Listed Transactions. Show all posts
Thursday, December 12, 2024

Guest Blog: Professors McGovern and Brewer on APA Status of Listed Transactions (12/12/24)

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I offer the second of two guest blogs from Bruce McGovern, Professor teaching tax law at the South Texas College of Law Houston (school resu...
Sunday, October 13, 2024

Treasury Promulgates Syndicated Easement Listed Transaction Regulations (10/13/24)

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The IRS long identified certain syndicated conservation easements as potentially abusive tax shelters. One prong of that attack Notice 2017-...
Sunday, June 16, 2024

Eleventh Circuit Invalidates IRS Designation of Listed Transaction by Notice; Designation Must be by Notice and Comment Regulation (6/16/24)

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In Green Rock LLC v. IRS , 104 F. 4th 220 (11th Cir. 6/4/24), CA11 here and GS here , the Court held invalid IRS use of subregulatory guida...
Thursday, March 3, 2022

Sixth Circuit Invalidates Notice Identifying Listed Transaction Requiring Reporting and Potential Penalties (3/3/22)

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In Mann Construction, Inc. v. United States , 27 F.4th 1138 (6th Cir. 3/3/22) CA6 here  and GS here , the Sixth Circuit panel held invalid I...
Tuesday, January 3, 2017

IRS Designates Syndications Exploiting Improper Valuations for Conservation Easement Deductions (1/3/17)

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This is a reposting of the same entry on my Federal Tax Crimes Blog. I note at a couple of places in the Federal Tax Procedure Book that s...