Subscribe to the Tax Headline RSS feed | Subscribe to the Tax Headline feed via EmailANALYSIS: The Wells Fargo Case and Economic Substance: Revisiting the Blueprint for Taxpayer Success
February 18, 2010 in Daily Tax Report · Leave a Comment
Nancy Bowen of Fulbright & Jaworski LLP follows up on an earlier Viewpoint article she co-authored that analyzed two recent taxpayer victories on economic substance: Consolidated Edison Co. v. United States and Shell Petroleum Inc. v. United States. The previous article identified common factors from the cases that provide a “blueprint for taxpayer success in proving economic substance,” Bowen writes, and the recent case of Wells Fargo & Co. v. United States “provides a unique opportunity to revisit and test the common factors that were identified…”
