2024-11-03
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 Tax Court case discussing section 304. After quoting section 304(a), the court stated:
Section 304(b) then helpfully sets out six paragraphs, ten subparagraphs, and dozens of clauses and subclauses to explain section 304(a). If these weren’t clear enough, there are also seven columns of single-spaced regulations. Secs. 1.304-1 through 1.304-5, Income Tax Regs. The result is a rococo fugue of tax law. [footnote 7]
[footnote 7] There is a custom of referring to the interplay of section 302 and section 318's family attribution rules as a "baroque fugue," * * *. Adding section 304 makes the fugue rococo.
Hurst v. Commr., 124 T.C. 16 (2005).