Substance over Form: No Friend of the Taxpayer

In the recent Messina case, the Ninth Circuit Court of Appeals affirmed the decision of the Tax Court denying S corporation shareholders losses as a result of lack of basis, particularly in this case, debt basis. In rendering their opinions, the Ninth Circuit and Tax Court discussed a taxpayer’s ability to argue substance over form…
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[**Practice Alert: Corporate Transparency Act is Here: What You Need to Know**](https://esapllc.com/practice-alert-cta-mar-2024/)
[**Practice Alert: Corporate Transparency Act is Here: What You Need to Know**](https://esapllc.com/practice-alert-cta-mar-2024/)