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Analysis

Tax Court Substance Ruling Offers Silver Lining For Taxpayers

By Kat Lucero ( November 19, 2025, 3:35 PM EST) -- Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions....

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