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 do not quarrel with the maxim that substance must prevail over form, but this proposition marks the beginning, not the end, of our inquiry. The court in Sheppard v. United States * * * perceptively remarked that “all such ‘maxims’ should rather be called “minims' since they convey a minimum of information with a maximum of pretense.” * * * Each case requires detailed consideration of its unique facts.
Grove v. Commr., 490 F.2d 241 (2d Cir. 1973)