OrbitaxUS Federal Court of Appeals affirms denial of loss deduction for lack of economic substance
|Approved Changes|United States
The US Federal Court of Appeals for the Sixth Circuit has disallowed a deduction for a loss from a transaction that was lacking in economic substance (Mark L. Kerman and Lucy M. Kerman v. Commissioner of Internal Revenue, No. 11-1822, 8 April 2013).
The case involved a US taxpayer who entered into a complex series of transactions, referred to as the Custom Adjustable Rate Debt Structure (C…
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