Are Internal Born-to-Die Letter Rulings About to Go Away?

Philip Levine and Britt Haxton were cited as authors of an earlier article on IRS LTR 201538015, which pointed out that the agency’s position on the ruling in the context of Section 355(e) “was precisely the same as the one the Supreme Court rejected in Gregory v. Helvering, the seminal step transaction/substance-over-form case.”