Abstract
The puropse of this paper is to review the history and background of bootstrap transactions and to determine: (1) Whether there is a need to close the bootstrap loophole; (2) If so, why this loophole has not been closed in the past; (3) Whether the Internal Revenue Code as it now exists contains provisions, if used, that can close this loophole; (4) If new legislation would be required to reach this end. A few key cases will be reviewed and analyzed, with major emphasis placed on the recent Clay Brown' decision, to show the attitude toward bootstrap transactions of both the Internal Revenue Service and the courts.
Recommended Citation
Frank C. Fogl Jr., The Bootstrap Loophole: Can It Be Closed, 16 Clev.-Marshall L. Rev. 370 (1967)
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