Monday, June 28, 2010
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC), has published Making Litigation Complex, 127 Tax Notes 1483 (June 28, 2010). Here is the abstract:
A primary cause of the length and complexity of recent tax litigation is the government’s assertion of the economic substance doctrine. Although the government’s intent seems to be to frighten people away, once the doctrine is unleashed, the government can’t control what it will do, including possibly upsetting previously settled law.
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