The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions.
In a July 19, 2024, order in Patel v. Commissioner,2 the Tax Court requested briefs from the parties and amici curiae on whether Section 7701(o) of the Internal Revenue Code requires a threshold relevancy determination before applying the codified economic substance doctrine, and if so, the circumstance(s) in which the economic substance doctrine is “relevant” within the meaning of Section 7701(o).
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