New Economic Substance Law Seen Helping IRS in Cases Similar to ‘Shell'

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A July 2008 district court loss for IRS in a case involving the economic substance doctrine does not mean that the service would not take the same position again in a future case, Associate Chief Counsel (Corporate) Alexander suggests. In a speech to a tax institute sponsored by Penn State Dickinson School of Law and the Association of the Bar of the City of New York, Alexander says that even after the service's loss in Shell Petroleum Inc. v. United States, he might remain “unrepentant” if another case with similar facts were to cross his desk.