Andantech L.L.C., Wells Fargo Equipment Finance, Inc. (f.k.a. Norwest Equipment Finance, Inc.), Tax Matters Partner, and Wells Fargo & Co., A Partner Other Than the Tax Matters Partner, et al. - Page 88




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               articulate some business purpose allegedly motivating the                
               indirect nature of the transaction or (2) point to an                    
               economic effect resulting from the series of steps, would                
               frequently defeat the purpose of the substance over form                 
               principle.  Events such as the actual payment of money,                  
               legal transfer of property, adjustment of company books,                 
               and execution of a contract all produce economic effects                 
               and accompany almost any business dealing.  Thus, we do                  
               not rely on the occurrence of these events alone to                      
               determine whether the step transaction doctrine applies.                 
               Likewise, a taxpayer may proffer some non-tax business                   
               purpose for engaging in a series of transactional steps                  
               to accomplish a result he could have achieved by more                    
               direct means, but that business purpose by itself does                   
               not preclude application of the step transaction                         
               doctrine. * * *                                                          
          Id. at 1177.                                                                  
               Under the step transaction doctrine, a series of formally                
          separate steps may be collapsed and treated as a single transaction           
          if the steps are in substance integrated and focused toward a                 
          particular result.  Courts have applied three alternative tests in            
          deciding whether the step transaction doctrine should be invoked in           
          a particular situation; namely, (1) if at the time the first step             
          was entered into, there was a binding commitment to undertake the             
          later step (binding commitment test), (2) if separate steps                   
          constitute prearranged parts of a single transaction intended to              
          reach an end result (end result test), or (3) if separate steps are           
          so interdependent that the legal relations created by one step                
          would have been fruitless without a completion of the series of               
          steps (interdependence test).  See Penrod v. Commissioner, supra at           
          1428-1430.  More than one test might be appropriate under any given           
          set of circumstances; however, the circumstances need satisfy only            






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