[yieldcrv]

it just means a tax authority disagrees with someone rich enough to see what a court thinks

public servants don’t know their laws better than private lawyers do, one of the beauties of using lawyers is that the public servants don’t know which legal rationale you are using and have no way to find out except in the court.

this is often a deterrent for them to bother, because they know they can be wrong or completely blindsided by a mixture of laws they never considered.

in this case, it wasn't a deterrent and we will find out.

but just because a tax authority disagrees doesnt mean the defendant was not compliant according to the law. it means the calculators are different and everyone has to figure out why.