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Abstract: 

In the last 68 years, courts have been applying various common law doctrines, including substance over form, step transaction, business purpose, sham transaction, and economic substance, in rendering tax decisions. An important feature of the common law doctrines, however, is that they overlap each other in many cases, and it is not uncommon that a court decides to deny or not to deny benefits on the grounds of more than one doctrine.

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Affiliations:  1: Ernst & Young LLP.