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the formalisms chosen by the participants. “The intent we focus on
under the end result test is not whether the taxpayer intended to
avoid taxes. * * * Instead, the end result test focuses on whether
the taxpayer intended to reach a particular result by structuring
a series of transactions in a certain way.” True v. United States,
190 F.3d at 1175.
Under the end result test, there is no independent tax
recognition of the individual steps unless the taxpayer shows that
at the time the parties engaged in the individual step, its result
was the intended end result in and of itself. Id. If this is not
what was intended, then we collapse the series of steps and give
tax consideration only to the intended end result. Id. “The
doctrine derives vitality, rather, from its application where the
form of a transaction does not require a particular further step be
taken; but, once taken, the substance of the transaction reveals
that the ultimate result was intended from the outset.” (Emphasis
in original.) King Enters., Inc. v. United States, supra at 518.
Applying the end result test to the sale-leaseback transaction
at issue, we examine whether Comdisco and Norwest intended from the
outset to transfer the benefits and burdens of the sale-leaseback
of the equipment to RD Leasing. If the intended end result was for
RD Leasing to have those benefits and burdens, then petitioners
cannot claim a right to favorable tax treatment for the various
intermediate transactions leading up to that intended result.
The record clearly indicates that every step taken by the
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