Here, as in Rick v. Brandsema, there is only speculation as to whether capital gains tax on the auto business, Orient, will ever crystallise because it might never be sold. This “contingent liability” is thus fundamentally different in character from the contingent tax liability attaching to the tax shelters in Stein.
Get a full legal research memo!
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexsei.com.