Hello- The quote from J. Learned Hand re: "...arrange affairs so that taxes shall be as low as possible..., etc. stems from his 2nd Circuit Court of Appeals opinion deciding the case entitled Helvering v. Gregory; 69 F. 2d 809, 810 (2nd Circuit, 1934). Alternatively, Gregory v. Helvering; 293 U.S. 465, 55 S.Ct. 266, 79 L.Ed. 596, 97 A.L.R. 1355, 35-1 USTC P 9043, 14 A.F.T.R. 1191, (1935) is a Supreme Court decision, the opinion of which was written by Justice Sutherland. Regardless of who decided what, any reliance upon the Hand quote in... e.g. court, will more than likely be counter-productive. In this case, the tax commissioner rejected Gregory's tax machinations; then the tax board of appeals overruled the commissioner. Next the 2nd Circuit Court of Appeals, in the Hand opinion containing his famous quote, reversed the decision of the tax board of appeals. The case then landed on the docket of the U.S. Supreme Court; where the case was renamed Gregory v. Helvering; 293 U.S. 465, etc. The Supreme Court affirmed the Circuit Court's decision and Gregory's tax scheme was deemed "...in fact an elaborate and devious form of conveyance masquerading as a corporate reorganization..."; and, " ...the transaction upon its face lies outside the plain intent of the statute. To hold otherwise would be to exalt artifice above reality and to deprive the statutory provision in question of all serious purpose." In other words, the quote is quaint and superficially appealing... until you realize the quote falls into the category of "obiter dictum"; harboring no legally binding effect whatsoever. What would be worse than no legally binding effect, is to cite the quote (if you must) and then attribute it to the wrong case, especially when doing so inside a courtroom.