A Review of Cancellation-of-Indebtedness Income Timing and the Variance Doctrine — Current Federal Tax Developments
When advising clients on complex debt relief transactions, it is crucial to understand not only the substantive law governing the timing of income recognition but also the procedural prerequisites for challenging IRS determinations. The recent Summary Order issued by the United States Court of Appeals for the Second Circuit in Romeo Salta, Jr., Phyllis Polega…

