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Abstract: 

This article discusses three taxation-of-investments matters that, while important, didn’t seem to the editor to merit full articles by themselves: recent developments, both administrative and judicial, affecting the application of the economic substance doctrine; a significant case, Sophy v. Commissioner, that answers some vexing questions about the deductibility of qualified residence interest when unmarried joint owners are involved; and a private letter ruling that comes to an important conclusion about basis and related issues when an electric-generating facility is acquired subject to a facility-specific power purchase agreement.

Keywords: IRC Section 7701(0); CC-2012-008; Reddam v. Commissioner; Crispin v. Commissioner; Sophy v. Commissioner; PLR 2012-14-007; facility-specific power purchase agreement; depreciation

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