James and Martha Kuper and Charles and Kathleen Kuper, Cross-Appellees v. Commissioner of Internal Revenue, Cross-Appellant

How courts have described this case

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

• recharacterizing purported nontaxable contribution of stock as taxable exchange and dividend
• disregarding step that was “momentary stopover” unnecessary to desired exchange of assets
• “[T]he incident of taxation depends on the substance rather than the form of the transaction.”
• “A legitimate business goal does not grant taxpayer carte blanche to subvert Congressionally mandated tax patterns.”

Source: CourtListener parenthetical corpus (CC0).