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tion. See, e.g., Packard v. Commissioner, supra. However, an
intention to minimize taxes, standing alone, does not require
that the form of a transaction be disregarded. See, e.g., McLane
v. Commissioner, 46 T.C. 140, 145 (1966), affd. per curiam 377
F.2d 557 (9th Cir. 1967).
Substance over form and related doctrines all require "a
searching analysis of the facts to see whether the true
substanceof the transaction is different from its form or whether
the form reflects what actually happened." Harris v. Commis-
sioner, 61 T.C. 770, 783 (1974). The issue of whether any of
those doctrines should be applied involves an intensely factual
inquiry. See Gordon v. Commissioner, 85 T.C. 309, 327 (1985);
see also Bowen v. Commissioner, 78 T.C. 55, 79 (1982). In this
regard, we note that the issues presented in the instant cases
turn on the particular facts and circumstances established by the
record herein, and we do not intend to, and do not, provide
herein any resolution of the proper tax treatment of transactions
that may appear to be similar to those presented in these cases.
In deciding whether to apply substance over form and related
principles to the transactions at issue, we examine the relation-
ships among the persons involved in those transactions because
those relationships are factors that we may consider in deciding
whether those transactions should be ignored or recharacterized.
See Wrenn v. Commissioner, 67 T.C. 576, 584 (1976); Aiken Indus.,
Inc. v. Commissioner, 56 T.C. at 934. However, those transac-
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