Tenth Circuit Engaged in Lengthy Deliberation in Sala
In what is considered by many an anomaly among the so-called “Son-of-BOSS” cases, the IRS lost the trial of a refund claim before the United States District Court for the District of Colorado in 2008....
View ArticleTenth Circuit Reverses District Court in Sala
In a brief (and some might say terse) opinion, the Tenth Circuit has reversed the District Court in Sala v. United States, 552 F. Supp. 2d 1167 (D. Colo. 2008) (decision linked below). As many...
View ArticleSchizophrenic Application of Tax Penalties (Part I)
Based our recent post on the Sala decision here, we have had several comments inquiring about the varied application of penalties in the “tax shelter” cases. This is the first in a planned series of...
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