A few days ago, the United States Tax Court handed down its long-awaited decision in Avrahami v. Commissioner, 149 T.C. No. 7 (August 21, 2017). The 105-page opinion is not the slam-dunk for the IRS that most commentators anticipated, nor does the Tax Court give the taxpayer anything such as a free pass. Rather, Avrahami reflects a considerable evaluation of the facts …
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