Currently pending in several federal appeals courts is the validity of a recent regulation that says the IRS has six years, rather than the normal three, to audit and adjust a return when a taxpayer fails to properly report capital gain or loss due to a miscalculation of basis in property.

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If the IRS follows the same rule for event-type CVRs, the issuer recognizes no gain or loss on the CVR issuance, the repurchase of the CVR, or the lapse of the CVR, but a target shareholder generally must recognize an immediate capital gain or loss taking into consideration the fair market value of the CVRs received on the date of distribution.

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When you sell your MLP units, your capital gain may be larger (or the loss will be smaller).

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