7 canonical passages across 5 cases, quoted by 21 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Superior Trading, LLC v. Commissioner.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Superior Trading, LLC v. Commissioner Anchor | green | “there is not even a colorable basis for the tax shelter that mr. rogers created and the parties implemented.” | 3 |
| 2 | Superior Trading, LLC v. Commissioner | green | “an entity without economic substance, whether a sham partnership or a sham trust, is a sham either way and hence is not recognized for federal tax law purposes.” | 3 |
| 3 | Superior Trading, LLC v. Commissioner | green | “no joint business goal motivated the creation of warwick” | 3 |
| 4 | Superior Trading, LLC v. Comm'r | green | “alternative holdings, each by itself sufficient to sustain respondent's adjustments” | 3 |
| 5 | Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. Commissioner | green | “expenditures made in an attempt to obtain abusive tax shelter benefits are not ordinary and necessary business expenses or otherwise deductible under section 162(a).” | 3 |
| 6 | Gordon v. Commissioner | green | “formally separate steps in an integrated and interdependent series that is focused on a particular end result will not be afforded independent significance in situations in which an isolated examination of the steps will not lead to a determination reflecting the actual overall …” | 3 |
| 7 | Penrod v. Commissioner | green | “whether 'the steps are so interdependent that the legal relations created by one transaction would have been fruitless without a completion of the series.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.