Teruya Bros. v. Commissioner

How courts have described this case

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

• drawing an adverse inference from the taxpayer’s decision to use a qualified intermediary when it could have achieved the same result through a direct exchange but the direct exchange would not have received nonrecognition treatment
• looking to actual consequences of transaction to discern the taxpayer's intent
• “[T]ax classifications turn on the objective economic realities of a transaction rather than the particular form the parties employed.”
• looking to the actual consequences to discern a taxpayer’s intent
• looking to the actual consequences to discern a taxpayer’s intent
• looking to the actual consequences to discern a taxpayer’s intent

Source: CourtListener parenthetical corpus (CC0).