In 1934, Judge Learned Hand made the statement that a taxpayer, "[M]ay so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes."

Since that time, taxpayers and tax administrators have struggled in determining the line between legitimate tax planning and unacceptable tax shelters.

Discuss what you believe distinguishes a tax shelter from tax planning. Do you agree with Judge Learned Hand?