Use and Abuse of Section 704(c)

Cunningham, Laura

Journal: Florida Tax Review

Volume: 3

Year: 1998

Bluebook Citation: 3 FLA. TAX REV. (1998)

Author: Laura E. Cunningham: all 3 publications


Abstract

This article examines the section 704(c) regulations in detail, in an attempt to gauge the scope of the anti-abuse rule. Part II describes the history of section 704(c) and the regulations construing it. Part III evaluates the anti-abuse rule in particular. It concludes that a narrow reading of the rule is appropriate and consistent with subchapter K as a whole.

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