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considering all of them as an integrated whole.” Packard v.
Commissioner, 85 T.C. 397, 420 (1985).
There is no universally accepted test as to when and how the
step transaction doctrine should be applied to a given set of
facts; however, courts have applied three alternative tests in
deciding whether to invoke the step transaction doctrine in a
particular situation: the “binding commitment,” the
“interdependence,” and the “end result” tests. Cal-Maine Foods,
Inc. v. Commissioner, 93 T.C. 181, 198-199 (1989); Penrod v.
Commissioner, supra at 1429-1430. Respondent relies in the
instant cases on the “end result” and “interdependence” tests.
Under the “end result” test, the step transaction doctrine
will be invoked if it appears that a series of separate
transactions is made up of prearranged parts of a single
transaction, cast from the outset to achieve the ultimate result.
Greene v. United States, 13 F.3d 577, 583 (2d Cir. 1994);
Associated Wholesale Grocers, Inc. v. United States, 927 F.2d
1517, 1523 (10th Cir. 1991). The end result test is particularly
pertinent to cases involving a series of transactions designed
and executed as parts of a unitary plan to achieve an intended
result. Kanawha Gas & Utils. Co. v. Commissioner, 214 F.2d 685,
691 (5th Cir. 1954), revg. 19 T.C. 1017 (1953). The series of
closely related steps in such a plan is merely the means by which
to carry out the plan, and the steps will not be separated. Id.
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