The Step Transition Doctrine: What Factors Will Affect The Courts Decision?

Main Article Content

Darlene A. Smith

Keywords

logit analysis, Tax Court cases, logit model

Abstract

Logit analysis was used to evaluate the factors considered by the Tax Court in deciding step transaction doctrine cases. Using a sample of 117 Tax Court cases, a logit model was estimated based upon eight variables. The existence of a preconceived plan and the economic interdependence of the steps were identified as the variables mostly likely to affect the decision of the Tax Court.

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