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Famous Tax Quote #2 - What Actually Occurred

2009-07-05

Continuing our series on Famous Tax Quotes, today's Famous Tax Quote is:

[A] transaction is to be given its tax effect in accord with what actually occurred and not in accord with what might have occurred. * * *

[W]hile a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax consequences of his choice, whether contemplated or not. 

Commissioner v. National Alfalfa Dehydrating, 417 U. S. 134 (1974).

Andrew Mitchel is an international tax attorney who advises businesses and individuals with cross-border activities.

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