David Berkowitz, Eat Your Heart Out

I'm not dead; not kidnapped. I'm just doing a big rush job right now. I'll go back to real posts tomorrow.

If you're a big Son of Sam - er - fan, you'll love this:

Son of Boss is the government’s name for a very technical, multi-step tax shelter “transaction” that was heavily marketed to high-wealth individuals, allowing them the opportunity to generate tax losses without incurring substantial economic risks or real economic losses. Son of Boss deals typically utilized a combination of the technical tax laws applicable to securities dealers, currency options, partnerships and partnership interests to inflate the basis in a foreign currency investment, which would then be sold at a large loss.

The techniques used to carry out Son of Boss deals were formally identified as abusive “listed transactions” by the Service in 1999, and again in 2000. However, these deals continued to be marketed and sold to taxpayers in 1999-2001, and beyond.

The Service discovered the widespread marketing of these transactions and filed lawsuits to obtain memoranda and investor lists from firms whose clients had engaged in Son of Boss deals. Moreover, the Service, in conjunction with the United States Department of Justice and State prosecutors, has conducted criminal investigations related to the promotion of Son of Boss shelters.

As these civil and criminal matters proceed, many of the taxpayers who “bought” the Son of Boss deals have joined in large civil lawsuits against entities involved in the sale of the shelters. Although at least one major taxpayer initiated has been settled by the law firm accused of fraud, civil law suits – along with criminal investigations – are likely to remain unresolved for years. Based on the significant dollars at issue, it appears that the Son of Boss will not be quickly laid to rest.

And:

"Son of Boss" is a spinoff of another tax shelter known as "BOSS," an acronym for Bond and Option Sales Strategy.