• Tax Officer Failed to Write His Own Opinion
  • October 3, 2012 | Author: Jasper L. (Jack) Cummings
  • Law Firm: Alston & Bird LLP - Durham Office
  • The Tax Court applied the economic substance doctrine in Gerdau MacSteel, Inc., 139 TC No. 5 (August 30, 2012), and denied penalty relief in a liability management company “tax shelter” case because the company’s tax department failed to either obtain an outside opinion or write its own.