2025-02-10
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:
[T]he Court attempted during oral argument to pin the government down on the precise meaning and scope of the U.S. Law Limitation, but that proved to be “an effort to nail jello to a wall.”
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The government’s explanation in a nutshell amounts to this: the Treaty governs unless it doesn’t.Bruyea v. United States, 134 AFTR 2d 2024-6310 (quoting from Alexander v. Mayhew, 334 F.R.D. 626, 627 (N.D. Fla. 2020)).