2010-06-06
Continuing our series on Famous Tax Quotes (quotes from court opinions with language that is colorful or that concisely states an important tax principle), today's tax quote is:
There is no real difference between the business purpose and the economic substance rules. Both simply state that the Commissioner may look beyond the form of an action to discover its substance.
Zmuda v. Commissioner, 731 F.2d 1417 (9th Cir. 1984)
This quote is particularly relevant with the recent enactment of Code § 7701(o) ("Clarification of Economic Substance Doctrine").
DISCLAIMER
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
65 Main Street, Centerbrook, Connecticut, 06409 USA | Ph: (860) 767-4975 | Fax: (860) 756-0954
Copyright © 2004 – 2024, Andrew Mitchel LLC. All rights reserved.