The Internal Revenue Service just lost a six billion dollar case with the stroke of a federal judge's pen. The IRS had challenged the "Son of Boss" tax shelter invented by KPMG, and Judge T. John Ward ruled against the IRS' attempt to retroactively apply its revocation of the tax shelter. Generally speaking the IRS code itself prevents its retroactive application, but when you're talking lost revenues in the multiples of billions and you're the IRS, well . . . you try anyway.
According to the New York Times, the "Justice Department declined to comment on the ruling. Donald L. Korb, the I.R.S.ís chief counsel, said in a statement that the agency 'was still studying the opinion.' "