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notice 2001-17 described a listed transaction known as a contingent liability tax shelter if the taxpayer had certain contingent liabilities it would form a new subsidiary corporation and contribute cash along with the contingent liabilities down to the subsidiary corporation although the liabilities were contingent they could often be valued under statistical analysis thus the amount of the cash contributed was just enough to cover the contingent liabilities under prior law the taxpayer would obtain an increase in basis in the shares of the subsidiary but not have to reduce the basis of the shares for the contingent liabilities assumed the result was that the taxpayer would have a high tax basis in the shares of the subsidiary but the economic value of the shares would be low because of the contingent liabilities held by the subsidiary the taxpayer would then sell the shares of the subsidiary to an unrelated third party for a low value the result would be that the taxpayer would recog

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