Tax,
Civil Litigation
Jun. 18, 2019
Altera redux—Will it get another bite at the APA?
Earlier this month, the 9th Circuit issued its new opinion in Altera v. Commissioner. Like last year’s opinion, which was subsequently withdrawn, the result is disappointing for taxpayers, but with so much at stake it seems inevitable that the decision will be appealed.
Peter J. Connors
Partner
Orrick, Herrington & Sutcliffe LLP
Peter is chair of Orrick's International Tax Practice.
Earlier this month, the 9th U.S. Circuit Court of Appeals issued its new opinion in Altera v. Commissioner, 2019 DJDAR 4948 (June 7, 2019) (Altera II). Like last year's opinion (Altera I...
To continue reading, please subscribe.
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!
Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)
Already a subscriber?
Sign In