Continuing our series on Famous Tax Quotes (quotes from court opinions with language that is colorful or that concisely states an important tax principle), today's tax quote is:
There is no real difference between the business purpose and the economic substance rules. Both simply state that the Commissioner may look beyond the form of an action to discover its substance.
Zmuda v. Commissioner, 731 F.2d 1417 (9th Cir. 1984)
This quote is particularly relevant with the recent enactment of Code § 7701(o) ("Clarification of Economic Substance Doctrine").