Forbes Quotes Charles Ruchelman: Supreme Court Sides With IRS In Tax Shelter Penalty Case
Forbes spoke with Charles M. Ruchelman concerning the U.S. Supreme Court's unanimous decision to uphold a 40% gross valuation misstatement penalty on a taxpayer who participated in a Son-of-Boss tax shelter. For the complete article, please visit Forbes' website.
Excerpt taken from the article.
"We have resolution now of an uncertainty in interpreting these complicated tax partnership provisions and their interplay with the penalty provisions," says Charles Ruchelman, a tax controversy lawyer with Caplin & Drysdale in Washington, D.C. who was not involved in the case before the Supreme Court. "There's a lot of money involved, and there are a lot of cases waiting out there across the country," he added.
Since these are partnership level proceedings, and the tax is determined at the partner level, it's hard to determine the amount of tax and penalty at issue for the partners, Ruchelman says, but suffice it to say, we're talking about millions of dollars in just this one case.