Publications Memos Go Back Trust Preferred Securities - Enron Case 04.29.98 This memorandum discusses the disallowance by the Internal Revenue Service of interest deductions taken by Enron in connection with two preferred securities transactions entered into in 1993 and 1994. Related Insights 08.05.26 | Publications IRS Notice 2026-36 on Section 4960 08.05.26 | Publications Debt-For-Equity Exchanges Developments – New FINRA Rule 01.20.26 | Publications Fifth Circuit Rules That Soroban Was Incorrectly Decided and SECA Tax Exception Applies to Limited Partners With Limited Liability Regardless of Activities Related Services Related Practice Areas Tax