PRACTISING LAW INSTITUTE - Steptoe & Johnson

In a footnote, the court, citing Otey and Treas. Reg. §§ 1.721-1(a) and 1.731-1(c)(3), suggested that, even if the court accepted the taxpayer’s characterization of the transactions, the fact that the cash received by the taxpayer ultimately came from the other three individuals … ................
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