2015-01-01
Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is:
Residence * * * has an evasive way about it, with as many colors as Joseph's coat. * * * The determination is factual and must be made through a consideration and balancing of all the elements involved.
Adams v. Commr., 46 T.C. 352 (1966)
[Note that this case dealt with old U.S. income tax residency rules under Treas. Reg. §1.871-2.]
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