Wednesday, June 28, 2006

Funny (if you're familiar with subchapter K) but true

Here's a clever summary of Treas. Reg 1.704-1(b) regs regarding the test for substantial economic effect:

"Any division of tax benefits and burdens, even one that is motivated by and in fact results in tax avoidance is permissible so long as the improper tax avoidance intent is undetectable to a nearly blind and deaf observer."

From "TOWARDS EQUITY AND EFFICIENCY IN PARTNERSHIP ALLOCATIONS" by Darryll K. Jones. (25 Va. Tax Rev. 1047)

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