Frank Lyon Co. v. United States

Holding that a “genuine multiple-party transaction” had economic substance, and distinguishing more “familial” arrangements involving only two parties

Comm'r v. Court Holding Co.

Holding that the Tax Court was justified in relying on the economic substance doctrine to "attribut[e] the gain from the sale to respondent corporation."

Knetsch v. United States

Holding that the purchase of several annuity bonds was substantively a sham, and should therefore be disregarded in determining the validity of claimed income tax deductions, where the premiums were paid by loans secured by the bonds and additional borrowing reduced the annuity each bond would pay from tens of thousands to a pittance

Commissioner v. Tower

Holding that federal law governs whether parties formed partnership for tax purposes

Commissioner v. Clark

Holding that a provision exception "is usually read narrowly in order to preserve the primary operation of the provision"

Horphag Research Ltd. v. Garcia

Recognizing that a district court's determinations at the preliminary injunction stage were "unavailing because such findings were made before discovery was completed and before the evidence was fully developed at trial and were thus not binding on the court at the summary judgment stage"

Gitlitz v. Commissioner of Internal Revenue

Reversing the Tax Court and the Tenth Circuit's interpretation of an "item of income" within I.R.C. § 1366, reasoning, "[b]ecause the Code's plain text permits the taxpayers here to receive these benefits, we need not address [the potential double windfall] policy concern"

Coltec Industries, Inc. v. U.S.

Holding that "the transaction to be analyzed is the one that gave rise to alleged tax benefit" and rejecting taxpayer's argument that economic substance test requires consideration of broader set of transactions

Commissioner v. Gordon

Holding that "if one transaction is to be characterized as a 'first step' there must be a binding commitment to take the later steps"

E.E.O.C. v. Prospect Airport Servs., Inc.

Finding that plaintiff "unquestionably established a genuine issue of fact regarding whether the conduct was welcome" because, among other reasons, he "swore under oath that it was not," and "[i]t made him cry, both at the time and repeatedly in the deposition"

Rule 56 - Summary Judgment

Holding a party may move for summary judgment on any part of any claim or defense in the lawsuit

Section 170 - Charitable, etc., contributions and gifts

In § 170 and § 501(c)(3), Congress has identified categories of traditionally exempt institutions and has specified certain additional requirements for tax exemption.

Section 1366 - Pass-thru of items to shareholders

Limiting pass-through deductions that shareholder may claim to "shareholder's basis in stock and debt"

Section 1377 - Definitions and special rule