Buy-and-sale-back transaction tax avoidance: related transactions and losses ignored where corresponding income is excluded. Buy-and-sale-back securities transactions are treated as ignored for tax computation if the interest or return to the other person is not included in that person's total income. Losses arising to a person from such transactions are similarly ignored for computing total income when related income on the security is not included, and any disallowed loss is limited to the amount of that excluded income.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Buy-and-sale-back transaction tax avoidance: related transactions and losses ignored where corresponding income is excluded.
Buy-and-sale-back securities transactions are treated as ignored for tax computation if the interest or return to the other person is not included in that person's total income. Losses arising to a person from such transactions are similarly ignored for computing total income when related income on the security is not included, and any disallowed loss is limited to the amount of that excluded income.
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