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References
- ↑ Keinan, Yoram (2007). "Rethinking the Role of the Judicial Step Transaction Principle and a Proposal for Codification" (PDF). Akron Tax Journal . 22: 45.
As early as 1938, the United States Supreme Court has indicated that "a given result at the end of a straight path is not made a different result because reached by following a devious path."
- ↑ Commissioner v. Clark, 489 U.S. 726, 738 (1989).
- ↑ Rosenberg, Joshua (November 1988). "Tax Avoidance and Income Measurement". Michigan Law Review. 87 (2): 365–497. doi:10.2307/1289221. JSTOR 1289221.
- ↑ Commissioner v. Gordon, 391 U.S. 83, 93 (1968).
- ↑ Paul, Randolph; Zimet, Phillip (1938). "Step Transaction". Selected Studies in Federal Taxation.
- ↑ Long-Term Capital Holdings v. United States ,330F. Supp. 2d122(D. Conn.2004).
- ↑ Commissioner v. Court Holding Co., 324 U.S. 331 (1945).
- ↑ Kimbell-Diamond Milling Co. v. Commissioner, 14T.C.74 (1950).