Just as the Internal Revenue Service was becoming increasingly more aggressive in its settlement offers in tax shelter cases, and obtained a few additional weapons for its arsenal in the American Jobs Creation Act of 2004, a series of defeats on the litigation front may force the agency to reevaluate some aspects of its strategy.

While the IRS continues to score some significant judicial victories in the shelter area, when it is trying to push more taxpayers toward coming forward and settling, it is most helpful for it to have a solid record of judicial support behind it.

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