According to this article in Tax Notes published by Tax Analysts, litigants attempt to characterize and categorize tax consequences through tax allocation language and tax reporting language. Generally this is a good idea because it helps to avoid misunderstandings and disappointment, and sometimes, even further litigation.
However, is this language binding and, if so, on whom – the parties; the court; the state taxing authorities; the IRS? Read this interesting article to find out.
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