Hindsight is 20/20: JM Assets and the Blow to Tax Certainty

As seen in Procedurally Taxing - Tax Notes Federal

In this article, the first of a two-part series, Managing Director Jenni Black examines the Tax Court opinion in JM Assets, and she argues that by determining reg. section 301.6235-1(b)(2)(i) is “invalid,” the court opinion removes quite a bit of certainty for both taxpayers and the government.

Explore the second article of the series as Jenni continues her examination of JM Assets LP, questions whether the Tax Court actually held reg. section 301.6235-1(b)(2) was invalid and discusses the impact the opinion has on tax certainty.