[DeFault User]

I noticed that no court has ruled on the tax status of the shelters.

[Poodlebrain]

Yes, but KPMG was willing to pay $456 million in fines for services it acknowledges charging only $115 in revenue for. KPMG obviously was not comfortable with its position if it was willing to walk away losing that much money on the concepts.

I'd like to know just what the economic substance of the purported transactions were that they would create such losses for KPMG's clients, and the clients would be eager to engage in such transactions purportedly costing them billions in losses.