An understanding of the scope of section 212(3) requires an examination of several factors: judicial and administrative law developed prior to its enactment; the events which precipitated its enactment; legislative conceptualization of its intended scope; judicial and administrative construction of the statute since its enactment; and the relationship of section 212(3) to other sections of the Code.
George L. Bevan Jr.,
Deductible Tax Planning Expenses: The Scope of Internal Revenue Code Section 212-3,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol11/iss2/8