id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-425	Hellwig, Brant J.; Polsky, Gregg D.	Litigation Expenses and the Alternative Minimum Tax	2004	49	.pdf	application/pdf	22746	997	56	The IRS has never taken this position [the transaction cost approach] with respect to attorney litigation fees, and you can bet that the business bar would vociferously oppose this treatment, since it would require attorneys fees incurred by plaintiffs in connection with multi- year business litigation to be capitalized and offset against the eventual recovery, or deducted as a loss at the time the litigation is unsuccessful, instead of being deducted when incurred by the taxpayer. Accordingly, this Article refers only to attorney's fees; however, the analysis is equally applicable to costs.	cache/ftr-425.pdf	txt/ftr-425.txt