On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more
12/20/2013
/ Asset Valuations ,
Income Taxes ,
IRS ,
Jurisdiction ,
Material Misstatements ,
Partnerships ,
Penalties ,
SCOTUS ,
Tax Shelters ,
TEFRA ,
Underpayment
Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more