Tuesday, August 17, 2004
As many readers of this blog know, Tax Analysts has a wonderful collection of quotations about taxes. Many of the quotations are from Tax Profs (including this one from your truly: “The tax bar is commonly referred to as a ‘special priesthood,’ and it is only slightly more tolerant than the Catholic Church in ordaining women tax priests.”).
The TaxProf E-Mail Discussion Group has had an interesting recent thread about other neat quotations about taxes. Elliott Manning (Miami) offers this gem on interpreting the Tax Code:
We here deal with problems arising under the Korean Excess Profits Tax Statute, as to which others have said, and we have echoed, that this statute “probably represented the most intricate and baffling enactment ever to receive Congressional approval.” As we struggle through this intricate web of definitions, exclusions, provisions, exceptions, cross references, limitations, provisos and a general but unavoidable obscurity, it is our conclusion that § 430(e)(2)(B)(i), expressly incorporating § 445(g)(2)(B), impliedly carries with it § 445(g)(3), though not necessarily that portion of § 461 impliedly incorporated by the reference to § 462(g) in § 445(g)(1), so that the attribution rules of § 503(a)(1)(2)(5) makes ownership of the corporate stock by the minor beneficiaries of a trust the ownership of the father, and thus pushes the stock ownership beyond the critical 50 per cent to make thereby a new corporation an old one.
Phinney v. Tuboscope Co., 268 F.2d 233, 234 (5th Cir. 1959) (citation omitted).
