Altria Group, Inc. v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• rejecting \certain or virtually certain” standard and approving jury’s consideration of \the likelihood that the tax-indifferent entity would exercise its fully-funded purchase option”
• stating, without explanation, that “[t]he substance over form doctrine and the economic substance doctrine are independent bases to deny a claimed tax deduction”
• affirming jury finding that a series of LILO and other transactions failed the substance over form inquiry
• \A reasonable jury could find that Altria did not retain assets of value at the end of the sublease terms; did not retain either the upside potential for economic gain or the downside risk of economic loss; and did not retain significant control over the facilities.\

Source: CourtListener parenthetical corpus (CC0).