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:
[W]e note that the regulations track the text of §956(d) nearly verbatim. The almost word-for-word match keeps the IRS’s terse explanation in line with the general principle that the more a regulation departs from a statute, the more an agency must explain itself. * * * Because the challenged regulations barely rocked the statutory boat, and because of the lack of public commentary and the straightforward nature of the regulations, little explanation was needed.
SIH Partners LLLP v. Commr., 923 F.3d 296 n.5 (3rd Cir. 2019).