2023-11-19
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 from a case where the judge is discussing the tax consequences of a sale of a partnership interest to the other partners versus a liquidation of the partnership interest by the partnership itself:
Yet the practical difference between [a sale of a partnership interest to the other partners] and one in which the withdrawing partner agrees merely to receive payments in liquidation directly from the partnership itself would hardly be a meaningful one in most circumstances. Why then the enormous disparity in tax burden, turning upon what for practical purposes is merely the difference between Tweedledum and Tweedledee * * *? The answer * * * is to be found in the legislative history of subchapter K * * *.
Foxman v. Commr. , 41 T.C. 535 (1964).