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Famous Tax Quotes - Plodding Through A Tax Court Opinion


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:

A modifying phrase is normally read to modify the nearest plausible antecedent. This rule is typically referred to as the “last antecedent” rule.

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The “anti-absurdity” canon of construction dates back many years. * * * (“If a literal construction of the words of a statute be absurd, the act must be so construed as to avoid the absurdity.”)

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Anyone who has managed to plod thus far through this Opinion will understand that the statutory provisions we are construing are extremely technical and complex.

Borenstein v. Commr., 149 T.C. No. 10 (2017).

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