What is the test for determining whether a tax motivated transaction constitutes a substantial underpayment of income tax?
MultiRegion, United States of America
The following excerpt is from Mosesian v. C.I.R., 967 F.2d 588 (9th Cir. 1992):
We review for clear error the tax court's determination that the taxpayers' income tax deficiency constituted a substantial underpayment of tax attributable to a tax motivated transaction, Kennedy v. C.I.R., 876 F.2d 1251, 1254 (6th Cir.1989).
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