Attorney-at-Law

THE SECRET SHARER – PART DEUX

In Uncategorized on 11/01/2018 at 14:49

Speaking of IRS’ regulatory overreach, here’s Good Fortune Shipping SA, Docket No. 25327-12, filed 11/1/18, with Ch J Maurice B (“Mighty Mo”) Foley bucking over to Judge Mary Ann (“She Abhors Cognomens”) Cohen DC Cir’s reversal of the Good Fortunates’ loss back in March, 2017.

For the skinny on bearer stock, unregistered type and the Section 883 largesse to certain maritime enterprises, see my blogpost “The Secret Sharer,” 3/28/17.

Notwithstanding subsequent changes in law, DC Cir comes down in favor of the Good Fortunates. See Good Fortunate Shipping SA v. Com’r, No. 17-1160 (DC Cir, 2018).

IRS’ categorical fling-out of bearer shares to satisfy the 50% test of ownership goes down, but the Good Fortunates must put in their proofs of who owned what where for the year at issue.

Take it away, Judge Cohen.

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