|Lawrence Hill: IRS will still issue regulations retroactively
The dispute originated when two North Carolina businessmen, who owned
a company called Home Oil and Coal, created Home Concrete to facilitate
a so-called Son of Boss tax avoidance scheme in 1999.
Boss is an acronym for bond and option sales strategies; Son of Boss
schemes essentially involve creating paper losses to offset real gains.
In May 1999, Home Concrete's shareholders carried out short sales of
US Treasury bonds. They made capital contributions of the proceeds of
the sales to Home Concrete, creating outside basis, or an interest in a
The following month, Home Oil made a capital contribution of
substantially all of its business assets to Home Concrete and, also as
capital contributions, the other taxpayers transferred percentages of
each of their partnership interests in Home Concrete to Home Oil.
The taxpayers filed their tax returns in 1999 and 2000,...
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