Tag Archives: Mayo v. United States

Carrying Out Agency Threats

by Andy Grewal — Sunday, July 19, 2015

In 1992, the IRS issued proposed regulations designed to combat a tax strategy used by the May Department Stores Company. Although the regulations were not immediately effective, the IRS announced that it when it finalized them, the regulations would apply retroactively to 1989. Consequently, some taxpayers took the proposed regulations into account in structuring their […]