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The narrowest alternative is the "binding commit-
ment" test, under which a series of transactions are
collapsed if, at the time the first step is entered
into, there was a binding commitment to undertake the
later step. See Commissioner v. Gordon, 391 U.S. 83,
96 (1968); * * *
At the other extreme, the most far-reaching alter-
native is the "end result" test. Under this test, the
step transaction doctrine will be invoked if it appears
that a series of formally separate steps are really
prearranged parts of a single transaction intended from
the outset to reach the ultimate result. See King
Enters., Inc. v. United States, 418 F.2d at 516; * * *
The third test is the "interdependence" test,
which focuses on whether "the steps are so interdepen-
dent that the legal relations created by one transac-
tion would have been fruitless without a completion of
the series." Redding v. Commissioner, 630 F.2d at
1177; * * *
Steps that are transitory, meaningless, or lacking in a non-
tax, business purpose may be disregarded for purposes of deter-
mining the true nature of a transaction. See Minnesota Tea Co.
v. Helvering, 302 U.S. 609, 613 (1938).
A transaction may be treated as a sham where a taxpayer is
motivated by no business purpose other than obtaining tax bene-
fits and the transaction has no economic substance because no
reasonable possibility of profit exists. See Rice's Toyota
World, Inc. v. Commissioner, 752 F.2d 89, 91-95 (4th Cir. 1985),
affg. on this issue 81 T.C. 184 (1983). Even if a transaction is
not a sham, it may still be recast in order to reflect its true
nature. See Packard v. Commissioner, 85 T.C. 397, 419-422
(1985).
Interposition of an intermediary between other persons in-
volved in a transaction may be disregarded under substance over
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