Guidance on making sure your transactions will pass muster under the Economic Substance, Sham Transaction, Substance over Form and related doctrines; determining when the IRS will respect a transaction as structured and when will it disregard the form of the transaction to disallow the claimed tax benefits; identifying situations where courts will uphold penalties imposed against taxpayers and discussion of what constitutes reasonable reliance on a practitioner for the purpose of avoiding penalties; review of recent case law as well as penalty and ethical standards.
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505 N Michigan Ave
Chicago, IL 60611
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