Tax cases can be interesting not only for the facts or legal issue involved, but also sometimes for how the judge writes the opinion. A recent example is Fresenius Medical Care Holdings, Inc. v. U.S., No. 13-2144 (1st Cir. 8/13/14). The tax issue was whether any portion of $385 million paid by the taxpayer to the government under a False Claims Act matter should be treated as a non-deductible penalty. There was already agreement that $101 million of the total of $486 million was a non-deductible criminal fine.
The legal issue is interesting, but I’ll save that for another post.