King Enterprises, Inc. v. The United States

How courts have described this case

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

• stating that the doctrine assures that “tax consequences turn on the substance of a transaction rather than on its form”
• stating that “the step transaction doctrine would be a dead letter if restricted to situations where the parties were bound to take certain steps” and refusing to apply the test
• characterizing “central purpose” of step transaction doctrine as assurance that “tax consequences turn on the substance of a transaction rather than on its form”
• applying step transaction doctrine under end result test after rejecting binding commitment test and without applying the interdependence test
• applying doctrine in treating stock acquisition followed by merger as a reorganization
• identifying “end result” and “interdependence” as the “two basic tests”

Source: CourtListener parenthetical corpus (CC0).