High Court's Tax Penalty Ruling Leaves Questions Unanswered

Law360, New York (December 3, 2013, 9:46 PM EST) -- The U.S. Supreme Court should have dug deeper into legislative history to anchor its Tuesday ruling that valuation misstatement penalties apply to certain tax shelter transactions, attorneys say, arguing the court's insistence on statutory plain meaning glossed over tensions that practitioners haven't been able to resolve.

Federal circuit courts had split over whether the penalty applies to partners in sham partnerships whose alleged misstatements stemmed from their claim of a tax basis, or investment, in a partnership interest that can't exist, because sham partnerships aren't recognized...
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