Corporate Taxpayers and Frivolous Arguments, Part 2

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

2024

Abstract

In my previous column, I discussed the Liberty Global cases and argued that the taxpayer’s positions were frivolous or lacked economic substance. I also argued that a corporate tax director who knows that a return position is frivolous or that a transaction has no economic substance should “just say no.” Until the day arrives that most tax directors take this view (I am not holding my breath), the IRS must rely on a combination of the uncertain tax position schedule and penalties under section 6662.

Comments

Reprinted with the permission of Tax Analysts.

Recommended Citation

Avi-Yonah, Reuven S. "Corporate Taxpayers and Frivolous Arguments, Part 2." Tax Notes Federal 183, no. 5 (2024): 867-870.