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:
[A]s a logical matter, [the taxpayer’s] receipt of the TBL GmbH stock in exchange for the transferred intangible property was a precondition to [the taxpayer’s] distribution of that stock * * *. The distribution could not have occurred until the exchange of property for stock had been completed: One cannot distribute what one does not have.
TBL Licensing LLC v. Commr., 158 T.C. No. 1 (2022)