2024-02-04
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 recent Tax Court case dealing with microcaptive insurance companies:
Although the Swift captives displayed some attributes of insurance companies, they failed to operate as insurance companies and their premiums were nonsense. We therefore conclude that the Swift captives did not provide insurance in the commonly accepted sense.
Swift v. Commr. , T.C. Memo. 2024-13.
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