Overview
Tax Analysts quoted Steptoe partner Aaron Nocjar in an article titled “IRS Reverses Position in New ‘Bad Boy’ Memo.” The article, published May 2, discusses a legal advice memo issued by the IRS making clear that common bad boy guidelines typically will not turn an otherwise nonrecourse loan into a recourse loan.
Mr. Nocjar says: “This new memorandum looks and feels like either a revenue ruling or notice on the topic that has been cloaked in a chief counsel memorandum. It would be beneficial to all taxpayers if Treasury/IRS removed that cloak in the near future, although I understand that resource constraints may serve as obstacles.”
The full article can be read at Tax Analysts (subscription required).
