In contrast, where cases involve straightforward business transactions, e.g., genuine debt instruments, the U.S. Tax Court has shown that it is generally favorable towards taxpayers. SeeNA General Partnership & Subsidiaries v. Commissioner, 103 T.C.M. (CCH) 1916 (2012) (ScottishPower); PepsiCo Puerto Rico, Inc. v. Commissioner, 104 T.C.M. (CCH) 322 (2012). For a more detailed analysis of these opinions, click here.The LILO/SILO Transactions –ConEdison,UnionBanCal and John Hancock Opinions issued by the Federal Circuit, Court of Federal Claims and Tax Court in 2013 mark the final group of opinions concerning LILO/SILO transaction cases.