Tag Archives: altera

Altera v. Commissioner: Heads the IRS Wins, Tails the Taxpayer Loses?

by Andy Grewal — Wednesday, Aug. 10, 2016

Altera v. Commissioner:  Heads the IRS Wins, Tails the Taxpayer Loses? Last year, in Altera v. Commissioner, the Tax Court dealt the IRS a major blow on rulemaking issues. In that case, the court held that some highly-controversial international tax regulations were invalid and thus could not apply in determining Altera’s tax liabilities for the […]