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The Role Of Economic Substance In Tax Shelter Controversies

By Herbert Odell, Philip Karter and Laura Ferguson
December 27, 2004

In its assault on corporate tax shelters, the Internal Revenue Service (IRS) ' with considerable help from Treasury and Congress ' has added new weapons to its arsenal and has honed its existing weaponry.

Tax Shelter Enforcement:
The Current Climate and the
Role of the Economic Substance Doctrine

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