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American Institute of CPA's on May 1, 1996. The length of the
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From the supplier: The US Court of Appeals for the 11th Circuit affirmed the Tax Court's ruling in Osteen that the taxpayer's losses were nondeductible because of lack of a profit motive under IRC section 183 but reversed the Tax Court's finding that the taxpayer's position lacked substantial authority. The IRS and the Tax Court had imposed a section 6661 substantial understatement penalty on the taxpayer for failing to demonstrate that there was substantial authority for claiming the deductions. The 11th Circuit directed the Tax Court to establish a workable substantial authority standard for cases such as this.
Citation DetailsTitle: Eleventh Circuit directs Tax Court to develop test for substantial understatement penalty.
Author: Peter C. Barton
Publication:The Tax Adviser (Magazine/Journal)
Date: May 1, 1996
Publisher: American Institute of CPA's
Volume: 27
Issue: n5
Page: 277(3)
Distributed by Thomson Gale.
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