- 34 - retroactivity to avoid inequitable results when taxpayers have entered into transactions in reliance on past regulations. That concern is simply not relevant when the taxpayer is requesting retroactive application of a new regulation. Remaining contentions not addressed herein we deem irrelevant, without merit, or unnecessary to reach. To reflect the foregoing and concessions by the parties, Decision will be entered under Rule 155.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34
Last modified: May 25, 2011