The full Tax Court declined to permit the IRS to disavow Rev. Rul. 78-197, upon which the taxpayers relied, and, thereby, used the anticipatory assignment of income doctrine to recharacterize the transfer of warrants in a soon to be acquired corporation t ...
Gerald A. and Henrietta V. Rauenhorst v. CIR
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IRS Cannot Disavow Revenue Ruling 78-197 to Recharacterize Charitable Donation
The full Tax Court considered whether the anticipatory assignment of income doctrine should be applied to recharacterize the transfer of warrants to four charitable organizations.