2020-10-25
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:
We cannot escape the conclusion that Rayben Limited was acting as a mere agency or instrumentality * * *. The whole transaction is not "in fact what it appears to be in form", and what was actually done "contradicts the apparent transaction." * * * We hold that Cohn, Inc., was the real owner * * *. "To hold otherwise would be to exalt artifice above reality." * * * We recognize that a taxpayer has the legal right to decrease the amount of what otherwise would be its taxes by means which the law permits. * * * But "fictional corporate camouflage cannot be made the device to escape taxation."
Kaspare Cohn Co. Ltd. v. Commr., 35 BTA 646 (1937)
Tags: Other - Famous Tax Quotes
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