Anti-Abuse Regulations
© Copyright 1998, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009 James Edward Maule
Applicable to all slides in set
Unauthorized copying, distribution, or use of these slides is a violation
of the Academic Rules of the Villanova Graduate Tax Program.
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Issued under sec. 701
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Designed to provide IRS a basis for attacking abusive
use of partnerships.
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Incorporate "common law concepts" such as
step transaction, business purposes, etc.,
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Not exclusive
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Do not pre-empt those doctrines.
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Apply only to the income tax, not estate and gift tax.
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Not intended to apply to bona fide business arrangements.
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Controversy over IRS power to issue these regs.
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- Spring '14
- JamesE.Maule
- Taxation in the United States, 1920, 1922, 1916, 1918, 1925
