Reconciling the "Irreconcilable" - 1(b)(1)-7(d)(1) Conflict; Understanding the "All Costs" Requirements to Mean "All Costs Shared by Arm's-Length Parties": Xilinx v. Comr. Revisited

Tax Management Memorandum, November 9, 2009

Lewis J. Greenwald authored "Reconciling the 'Irreconcilable' - 1(b)(1)-7(d)(1) Conflict; Understanding the 'All Costs" Requirements to Mean 'All Costs Shared by Arm's-Length Parties': Xilinx v. Comr. Revisited," which discusses the reversal by the Ninth Court of the Tax Court's decision in Xilinx v. Comr. The article appeared in the November 9, 2009 issue of Tax Management Memorandum, Vol. 50, No. 23.