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Navigating The Unsettled Listed Transaction Landscape

By Michael Waalkes
The CPA Journal
January 2024

Due to recent taxpayer-favorable court decisions requiring the Department of the Treasury to use formal notice-and-comment procedures under the Administrative Procedure Act (APA), the process by which the IRS publicly identifies listed transactions has undergone significant changes. It remains unclear whether these changes will ultimately have taxpayer-favorable effects, and CPAs are well advised to closely monitor developments.

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Published with permission from The CPA Journal © 2024, a publication of the New York State Society of Certified Public Accountants.