A federal appeals court affirmed a ruling Thursday that a family’s trusts are liable for nearly $80 million in unpaid taxes, penalties, and interest tied to a stock-sale transaction structured to avoid taxes on appreciated corporate assets.
The US Court of Appeals for the Federal Circuit affirmed a lower court’s decision that trusts represented by Dillon Trust Company were liable as transferees after selling stock in two companies—Humboldt Corp. and Shelby Corp.—to an intermediary entity that later engaged in abusive “Son-of-BOSS” tax shelter transactions.
“Son-of-BOSS transactions” are a complex tax shelter that generate artificial capital losses to offset large capital ...