Tax Coda

Tax Coda

Why foundational tax doctrines are back on the table

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Tax Coda
Jan 23, 2026
∙ Paid

Most tax cases do not change the law. They reinforce it. Courts apply familiar doctrines to familiar fact patterns and move on. That stability is not accidental. It reflects a system that values predictability over precision.

Every so often, though, courts are forced to revisit the foundations because administrative practice drifted and taxpayers adapted…

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