Moore 2.0? Analyzing Altria Group Inc. V. United States

NEW YORK – JANUARY 31: The former Philip Morris office building, now called Altria, is shown … [+] Tax Notes contributing editor Robert Goulder discusses the downward attribution dispute in Altria Group Inc. v. United States and the case’s similarities to Moore . This transcript has been edited for length and clarity. Tax Notes Talk Moore 2.0? Analyzing Altria Group Inc. v. United States January 19, 2024 More Tax Notes Talk David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax Notes Today International . This week: More after Moore . We’re back talking about Moore v. [ United States ], albeit indirectly this week. As we wait for the Supreme Court’s decision in that case, another big case is waiting in the wings. Altria [ Group Inc. ] v. United States has been referred to as Moore 2.0 by some in the tax world since the issues at the center of this case bear striking resemblance to the Moores’ arguments. To tell us more about this, I’m joined by Tax Notes contributing editor Robert Goulder. Bob, welcome back to the podcast. Robert Goulder: Hello, Dave. Thanks for having me. David D. Stewart: Now, just to start off, the name Altria rings a bell. What does that company do? Robert Goulder: Yes. Well, they maybe are not a household name, but they once were. It is the successor and interest to Philip Morris, the giant tobacco company. That business decided a number of years ago it needed to rebrand itself, so it adopted a new corporate slogan, “Moving Beyond Tobacco.” MORE FROMFORBES ADVISOR Best Tax Software Of 2022 Best Tax Software For The Self-Employed Of 2022 Income Tax Calculator: Estimate Your Taxes And they’re also now more of a diversified multinational. Yeah, they still […]

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