Sullivan
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Daniel Ryan was quoted in the article "Top Federal Tax Cases To Watch In 2nd Half Of 2025," published by Law360 Tax Authority [sub. req'd] on July 3, 2025. The article focuses on several noteworthy federal tax cases to follow throughout the remainder of 2025, including a New York federal court review of a government suit concerning allegations of fraudulent tax shelters known as "Son-of-Boss."

The IRS has aggressively pursued such abusive tax shelters, which use complex transactions to create artificial losses and limit tax liability on capital gains, with notable enforcement success. In 2024, the government brought a major case against Vance Finance and its former shareholders, alleging they evaded $81 million in taxes through such schemes, while the accused deny any awareness of wrongdoing.

Dan notes that the government is likely to press Vance Finance and the former investors using a "transferee theory," in which "there is a liability and assets were moved to other people."