2023-11-18
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:
One would not expect such a narrow rule, helpfully titled "Recapture of overall foreign loss" and adopted to limit a taxpayer's foreign tax credit, to serve the dual function of exempting billions of dollars of gain from U.S. taxation. As the Supreme Court has said, "Congress does not 'hide elephants in mouseholes' by 'alter[ing] the fundamental details of a regulatory scheme in vague terms or ancillary provisions.'"
Liberty Global, Inc. v. Commr. , 161 T.C. No. 10 (2023).
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