- 102 -
bright-line rules that will provide guidance to the business
community and the Internal Revenue Service and reduce the burdens
of compliance and controversy on the public, the Service, and the
courts. Sections 195 and 197 come to mind as possible starting
points or models.
GALE, J., agrees with this concurring in part and dissenting
in part opinion.
Page: Previous 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 Last modified: May 25, 2011