Analyzing the Constraints of the OECD Corporate Mediation Process
Tax Notes Talk
Oxford Paper Versus Commissioner
The leading case on the issue is a second circuit case named Oxford paper versus commissioner, which was decided in 1952. The IRS issued a published ruling revenue ruling 55-675 which followed the court's holding in Oxford paper. A more recent line of authority that some practitioners have interpreted as casting doubt on whether the Oxford paper case can still be relied on.
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