2025-11-13
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 from a Tax Court opinion that came out yesterday. Patel v. Commr., 165 T.C. No. 10 (2025).
[I]t is worthwhile to address the Patels’ argument that the economic substance doctrine does not apply when the taxpayer has engaged in a purported "Congressionally induced" or "Congressionally incentivized" transaction. * * *
[T]he primary issue in these cases is the deductibility of purported insurance premiums reported as ordinary and necessary business expenses under section 162. * * * [W]e previously concluded that the premiums paid and deducted by the Patels did not constitute insurance for federal tax purposes. * * * The Patels do not direct us to any congressional inducement to claim deductions for premiums for purported insurance that is not, in fact, insurance.
Ouch! 💥