10/23/2024
https://congress.gov...
"OK. Mr. Silber, do you know the point I am trying to make here? I am not trying to judge whether or not this was a controlled entity."
"So this is pretty unique?"
"So suffice it to say it is very difficult to comply----"
"Let me just ask: To what extent has this been adjudicated in any kind of tax court or through the IRS?"