Tax Headlines


Work-Product Doctrine Applicable to Documents Relating to Tax Shelter Transaction; Voluntary Disclosure of Documents Waived Tax Practitioner Privilege (Santander Holdings USA, Inc., DC Mass.)

Documents that provided advice regarding changes in the law in the United Kingdom and the United States and unwinding a corporation’s STARS transaction were protected from disclosure under the attorney-client and tax-practitioner privileges and the work-product doctrine.

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Leased Trucks Treated as Separate Items of Property, Income Recharacterized as Nonpassive (Veriha, TC)

Income from an individual’s trucking business was recharacterized as nonpassive after particular trucks leased to the individual were recharacterized as multiple “item[s] of property” under Reg. §1.469-2(f)(6) . The taxpayer owned and materially participated in a trucking business, and controlled two companies from which the trucking business leased its tractors and trailers. On his tax return, he listed income from one leasing company and a net loss from the other, both classified as passive under Code Sec. 469 .

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