In this week's Tax Geek Tuesday, we've been handed a case out of the Tax Court that serves up a veritable smorgasbord of statute, taking us through Sections 351, 1361, 1362, 368, 197, 167, 1239 and 267. More importantly, the court's decision in Fish v. Commissioner, T.C. Memo 2013-270, offers tax professionals a crucial reminder regarding mergers and acquisitions -- while we're free to structure our transactions in whatever manner we choose in order to achieve the desired tax result (subject to ...
In this week's Tax Geek Tuesday, we've been handed a case out of the Tax Court that serves up a veritable smorgasbord of statute, taking us through Sections 351, 1361, 1362, 368, 197, 167, 1239 and 267. More importantly, the court's decision in Fish v. Commissioner, T.C. Memo 2013-270, offers tax professionals a crucial reminder regarding mergers and acquisitions -- while we're free to structure our transactions in whatever manner we choose in order to achieve the desired tax result (subject to ...
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