Unformatted text preview: RedSox Corporation to provide evidence to the IRS which would rebut their position. If the first sale occurs three years before the second sale, the substantial length of time between the sales should make them immune from the step transaction doctrine. In general, transactions separated in time by more than 12 months are presumed to be independent. In other words, the initial transaction is “old and cold”....
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This note was uploaded on 09/09/2011 for the course TAX 6845 taught by Professor Kelliher,c during the Fall '08 term at University of Central Florida.
- Fall '08