More than a decade after the associated property rule was invalidated by the U.S. Court of Appeals for the Federal Circuit in Dominion Resources, Inc. v. United States, 681 F.3d 1313 (Fed. Cir. 2012), the U.S. Department of...more
The year 2012 was quite an interesting one for tax controversy. Whereas 2011 brought a win for the Treasury on deference issues in Mayo Foundation for Medical Ed. v. United States, 131 S. Ct. 704 (2011), 2012 was the year...more