A partner can't avoid a 40% penalty for gross valuation misstatement under Internal Revenue Code Section 6662(a) by conceding his tax-shelter case on other grounds, the U.S. Tax Court has ruled, striking down a common method used by taxpayers invested in tax shelters. The court declined to follow a precedent, noting that the majority of appeals courts have found the interpretation of underlying legislative history in those cases to be incorrect.

Related Summaries