Summary
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.
See Also
Gerald A. and Henrietta V. Rauenhorst v. CIR
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 ...