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Elliot Pisem and David E. Kahen, members of Roberts & Holland, write that one question that arises from time to time is whether a purchaser or seller of a business is bound for tax purposes by any contractual allocation of consideration, or whether a party may take a different tax return position that, if respected, would provide that party with a better tax result. A recent ruling in the First Circuit, they say, throws light on this issue.
February 19, 2009 at 12:00 AM
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