Limiting the Substance Over Form Doctrine
CTP
MARCH 30, 2023
At the end of 2018, to the dismay of the IRS and the Tax Court, the Second Circuit joined the First and Sixth in reversing the Tax Court’s decision in the Summa Holdings “substance over form” matter. The father and mother lived in New York and their two sons lived in Massachusetts. The Sixth Circuit in Summa Holdings, Inc.
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