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18 Dec 2009, 1:17 am
Kahen, members of Roberts & Holland, write that two recent decisions show that some lessons seem reasonably clear: it is generally helpful to focus on the intended tax reporting of the transaction in the transactional documents, such that the parties' reporting positions are reconcilable with each other; but, as the IRS will not be bound by any agreements or understandings between the lender and the borrower, it is also important to make sure that the parties comply with… [read post]