Notice 2017-10’s Demise May Be Imminent: Current Litigation Involving the Controversial IRS Rule
The state of litigation concerning listed transactions has changed dramatically since the Supreme Court’s unanimous decision in CIC Services, LLC v. Internal Revenue Service in May of 2021. Prior to the Court’s decision, the IRS relied on the Anti-Injunction Act to shield itself from litigation based on the Service’s failure to go through the required…
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