In the last few years, the State of New York has attempted to make major reforms to the state’s corporate income tax system. In the spring of 2014, Governor Cuomo signed into law the state’s annual budget which contained many…
Not knowing the details of a business transaction sounds preposterous on its face, especially when the ignorant taxpayer is the party which formulated the transaction. In the case of Makric Enterprises, Inc. v. Commissioner, TC Memo 2016-44, a failure to make…
Congress, aware that related parties could create fictitious tax losses lacking economic substance based upon the related parties continued enjoyment of the property subject to the loss, enacted § 267 of the Internal Revenue Code to disallow certain losses and…
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