Analysis

Tax Canon May Ensue If Justices Take $199M Deduction Case

By Amy Lee Rosen (May 18, 2018, 7:28 PM EDT) -- A Third Circuit ruling on appeal to the U.S. Supreme Court that prevented an electricity supplier from claiming a double deduction on a consolidated tax return has some practitioners worried that, if accepted, the justices could solidify a stand-alone tax doctrine previously used only as a method of statutory interpretation.

At stake is Pittsburgh-based Duquesne Light Holdings Inc.'s attempt to claim $199 million in tax deductions disallowed by the Internal Revenue Service. The energy services holding company tried to take advantage of a gap in regulations when it claimed a capital loss on the transfer of less than 20 percent of...

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