Not Enough Substance: the Eighth Circuit Looks at a Lease Restructuring Transaction.

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This piece summarizes a recent Eighth Circuit case that applied the economic substance doctrine to a lease restructuring transaction undertaken by Wells Fargo. The taxpayer lost primarily due to the court's refusal to accept a business purpose that the taxpayer found after concluding it wanted to undertake the transaction.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© James R. Malone, Jr., MALONE LLC | Attorney Advertising

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