Best of TaxLetter: Invasion of the Money Snatchers

Not all tax opinions are boring reading. Here is a paragraph from Judge Goldberg's ten page dissenting opinion (the majority opinion was one page) dealing with an interest-free loan case:

"The Invasion of the Money-Snatchers: The Attack of Form. The government has launched an attack on three fronts against a long-time arch enemy by relying exclusively on the artillery of a purely formalistic argument. The government's nemesis -- the problem of interest-free loans -- has successfully withstood formalistic IRS advances over the past two decades by seeking shelter in a fortress constructed upon an analysis of the policies underlying several provisions of the tax code."

(No. 26, 81-2 USTC Par. 9534)


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Created: March 21, 1996; Last updated: January 26, 2004
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