Baxter v. Comm’r of IRS (P)

On their 2000 tax return, taxpayers claimed substantial capital losses attributable to a Custom Adjustable Rate Debt Structure transaction, which the taxpayers relied on to offset capital gains attributable to the sale of their family business. The Tax Court properly concluded that the transaction lacked “economic substance” and, therefore, that the taxpayers wrongly relied on the transaction to offset their capital gains.


Baxter v. Comm’r of IRS (P), No. 17-2402, Dec. 7, 2018. 4th Cir. (Wynn) from U.S. Tax Ct.

Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published


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