Tag Archive for Shakespeare

Shakespeare, Building Your Vocabulary… And Taxes

TaxConnections Picture - Gavel House and Law Book 1 - square

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.

Here, I’ll just focus on the intriguing language of Judge Bruce M. Selya in writing the opinion. It includes footnote 5: Read more