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Tax Lawyer, Vol. 61, No. 1 TEXTUALISM AND INTENTIONALISM IN TAX LITIGATION 53Textualism and Intentionalism in Tax Litigation DaAvidID F. ShoOresES* I. IntroductionTax cases frequently turn on issues of statutory construction. The statute might be general in nature, such as section 162, which allows a deduction for “all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business.”1 Alternatively, the statute might be highly specific, providing...

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