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Expert Analysis

Mazzei Case Educed An Unusual Tax Court Response

By Lawrence Hill and Kevin Platt ( June 5, 2018, 5:49 PM EDT) -- On March 5, 2018, the United States Tax Court published a fascinating decision in Mazzei v. Commissioner of Internal Revenue,[1] siding with the assertion by the commissioner that the taxpayers' structure lacked economic substance. The opinion again demonstrates why the Tax Court is not a taxpayer-favorable forum to litigate tax-advantaged transactions, even those that are arguably sanctioned under the Internal Revenue Code. [2]. . .

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