Grimm v. A. Schraders & Son (1974)
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Penrod v. Commissioner (1987)
However, in contrast to the binding *108 commitment test, the end result test is flexible and bases tax consequences on the real substance of the transactions, not on the formalisms chosen by the participants. 10 The third test is the "interdependence" test, which focuses on whether "the steps are *109 so interdependent that the legal relations created by one transaction would have been fruitless without a completion of the series." Redding v. Commissioner , 630 F.2d at 1177…
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Estate of Christian v. Commissioner (1989)
The third test is the "interdependence" test, which focuses on whether "the steps are so interdependent that the legal relations created by one transaction would have been fruitless without a completion of the series." Redding v. Commissioner , 630 F.2d at 1177 ; see also Kass v. Commissioner , 60 T.C. 218 (1973) , affd. without published opinion 491 F.2d 749 (3d Cir. 1974) ; Farr v. Commissioner , 24 T.C. 350 (1955) ; American Wire Fabrics Corp. v. Commissioner , 16 T.C. 60…
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Shadd v. United States (1975)
See Henderson v. Goeke, 329 F.Supp. 1160 , 1162 fn. 5 (E.D.Pa.1971), aff’d 491 F.2d 749 (3rd Cir. 1973). 3 .
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Comm'r
The "interdependence" test focuses on whether "the steps are so interdependent that the legal relations created by one transaction would have been fruitless without a completion of the series." Redding v. Commissioner, 630 F.2d 1169 , 1177 (7th Cir. 1980) , revg. and remanding 71 T.C. 597 (1979) ; see also Kass v. Commissioner, 60 T.C. 218 (1973) , affd. without published opinion 491 F.2d 749 (3d Cir. 1974) ; *204 Farr v. Commissioner, 24 T.C. 350 (1955) ; Am.