2025-12-13
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:
[U]nder the economic substance doctrine a taxpayer cannot merely clothe itself in corporate jargon to point to a motivation other than tax avoidance. But * * * this is not a demanding standard for the taxpayer either. * * * After all, “[t]ax planning is as American as apple pie.” [quoting from Bittker & Lokken, Federal Taxation Of Income, Estates And Gifts]
Perrigo Co. v. U.S., No. 1:17-cv-00737 (U.S. Distr. Ct., West. Distr. Mich., Sept. 25, 2025).