The Fabricated Unwind Doctrine: The True Meaning of Penn v. Robertson

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Title

The Fabricated Unwind Doctrine: The True Meaning of Penn v. Robertson

Content partner

The University of Auckland Library

Collection

ResearchSpace@Auckland

Description

When taxpayers discover that their transactions have unwanted tax consequences, they routinely rely on the unwind doctrine found in Internal Revenue Service Revenue Rulings 80-58. Nowadays, “unwinding” has become a “common if not ubiquitous feature of tax practice.” This article finds that the unwind doctrine has no firm basis in case law. Instead, the unwind doctrine is an Internal Revenue Service (IRS) fabrication based on the IRS’s misinterpretation of the case Penn v. Robertson 115 F2d 16...

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Format

Research paper

Research format

Journal article

Date created

2011

Creator

Prebble, J / Huang, Chye

URL

http://hdl.handle.net/2292/12202

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