Susan E. Seabrook, shareholder, and Caroline C. Setliffe, counsel, recently analyzed the precedential impact of Altera v. Commissioner, 145 T.C. No. 3 (2015) for BNA Tax Management. In this case, the Tax Court provided clarity about operational and administrative federal tax issues that have long been considered problematic. The IRS has 90 days to file notice of appeal from the Tax Court?s December 1 decision in Altera.
Read the full article - Altera: Rattling the IRS's Sense of Comfort in Its Rulemaking Process (Reproduced with permission from Tax Management Memorandum, 57 TM Memorandum 23, 1/25/16.)