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The Principal Purpose Test — A US Tax Court Preview

Law360 (May 14, 2018, 4:01 PM EDT) -- In the procedural maze that leads to a trial in the U.S. Tax Court, motion practice is an important part of tailoring issues presented to the court. In particular, motions to grant summary judgment are often filed by the IRS to preclude a full trial. According to Rule 121(a) of the U.S. Tax Court rules of practice and procedure, either the taxpayer or the IRS may submit a motion for summary judgment in its favor regarding all or any part of the legal issues in controversy....
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