Commissioner v. Court Holding Co.

How courts have described this case

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

• recognizing step transaction doctrine, whereby courts must consider all steps of transaction in light of entire transaction, so that substance of transaction will control over form of each step
• creating step transaction doctrine, whereby courts must consider all steps of transaction in light of entire transaction, so that substance of transaction will control over form of each step
• court may view transaction as a whole even if taxpayer accomplishes result by series of steps
• \[t]o permit the true nature of a transaction to be disguised by mere formalisms... would seriously impair the effective administration of the tax policies of Congress.\
• “To permit the true nature of a transaction to be disguised by mere formalisms ... would severely impair the effective administration of the tax policies of Congress.”
• courts must not “permit the true nature of a transaction to be disguised by mere formalisms, which exist solely to alter tax liabilities”

Source: CourtListener parenthetical corpus (CC0).