By Patrick Smith ( September 5, 2018, 5:48 PM EDT) -- On Tuesday, July 24, 2018, the U.S. Court of Appeals for the Ninth Circuit issued its much-anticipated opinion in Altera Corp. and Subsidiaries v. Commissioner of Internal Revenue,[1] a case that involves a challenge to the validity of regulations issued under Section 482 of the Internal Revenue Code. Although one of the judges on the Ninth Circuit panel wrote a dissent that would have affirmed the Tax Court's opinion, the decision was a severe disappointment for most tax professionals in private practice, as well as, presumably, the 15 U.S. Tax Court judges whose unanimous opinion[2] was reversed by the decision. But the majority opinion was undoubtedly a cause for celebration for the attorneys in the Internal Revenue Service Office of Chief Counsel and the U.S. Department of Justice Tax Division, as well as for the multiple law school professors who had filed amicus briefs in support of the IRS in the Ninth Circuit....