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or steps will not necessarily be stepped together and ignored
where each such preliminary step constitutes a permanent
alteration of a previous bona fide business relationship. That
general statement in Rev. Rul. 79-250, however, does not preclude
application of the step transaction doctrine, the substance over
form doctrine, or the integrated transaction doctrine to the
facts of this case involving recapture of investment tax credit
under section 47. See also Associated Wholesale Grocers., Inc.
v. United States, supra at 1526-1527; Rev. Rul. 96-29, 1996-24
I.R.B. 5.
Based on the above authority, I believe that the majority
herein errs in suggesting, majority op. pp. 16-17, that the
business purpose associated with the transfer of petitioner’s
glass division to a subsidiary and with the change in ownership
of the subsidiary provides, for purposes of section 47 recapture,
the sum and substance of the transaction before us and
effectively precludes any meaningful analysis under the
substance-over-form, the step transaction, or the integrated
transaction doctrines.
A brief analysis of the substance and steps of the
transactions before us is appropriate.
The Court of Appeals for the Sixth Circuit, to which an
appeal in this case would lie, has adopted the end result
approach of the step transaction doctrine. In Brown v. United
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