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

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Darlene A. Smith


logit analysis, Tax Court cases, logit model


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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