Topic: the touchstone of economic reality is whether an outside le… · Go Syfert
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Topic #35781

2 canonical passages across 2 cases, quoted by 10 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 Segel v. Commissioner.

#Case FlagCanonical passage Citers
1 Segel v. Commissioner Anchor
· 1987
green “the touchstone of economic reality is whether an outside lender would have made the payments in the same form and on the same terms.” 7
2 Calumet Industries, Inc. v. Commissioner
tax · 1990
green “as a classic capital investor hoping to make a profit, not as a creditor expecting to be repaid regardless of the company's success or failure.” 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.

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