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International Tax Blog - New and Interesting International Tax Issues


Famous Tax Quotes - That’s How The Cookie Crumbles

2018-09-22

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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:

When filing their amended returns for 2004 and 2005, petitioners made voluntary, irrevocable elections under section 962. * * * By making these elections petitioners got what they bargained for * * * [T]hese elections may ultimately cause them to include more gross income than they would otherwise have had to include. Unfortunately, that is sometimes how the cookie crumbles.

Smith v. Commr., 151 T.C. No. 5 (2018).

Tags: 962 Election to be taxed as corporate rates, Other - Famous Tax Quotes