Eliyahu D. Jacobson

Economic Substance Doctrine: New Directive for IRS Examiners and Managers: LB&I Directive Sets Out Detailed Substantive and Procedural Standards for IRS Examiners to Follow - This Provides Valuable Information to Taxpayers and Their Advisors
David P. Hariton,Eliyahu D. Jacobson,Donald L. Korb,Andrew S. Mason,S. Eric Wang,Diana L. Wollman, July 28, 2011
The Commissioner of the Large Business and International Division of the IRS (“LB&I”) recently issued a directive (the “Directive”) to LB&I examiners and managers setting out specific analytical steps that the examiners must complete before asserting the newly codified...