id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-435	Shepard, Ira B.; McMahon, Jr., Martin J.	Recent Developments in Federal Income Taxation: The Year 2001	2022	162	.pdf	application/pdf	69594	3132	55	The tax court�s narrow notion of �business purpose�� which is admittedly implied by the phrase�s plain language � stretches the economic-substance doctrine farther than it has been stretched. 2164, 2171 (2001), �[t]he interpretation of Rev. Proc. 71-21 contained in the General Counsel Memorandum and the IRS decision under the Revenue Procedure is not reflected in a regulation adopted after notice and comment and probably would not be entitled to Chevron2 deference,� �[t]he Supreme Court has firmly established that agency interpretations of their own regulations are entitled to substantial deference.	cache/ftr-435.pdf	txt/ftr-435.txt