Law360, New York ( November 25, 2014, 11:05 AM EST) -- The U.S. Court of Appeals for the Second Circuit recently affirmed the Tax Court's 2013 decision in Barnes Group Inc. and Subsidiaries, T.C. Memo 2013-109, in which the Tax Court applied the step transaction doctrine to recharacterize a series of transactions employed by the taxpayer, a U.S. corporation, as part of its reinvestment plan. The result was a $58 million taxable dividend to the taxpayer, as well as the imposition of a 20 percent accuracy-related penalty, despite the taxpayer's claim that it reasonably relied on a revenue ruling and an opinion letter from its tax advisers....
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