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substance over formdisc roth irastatutory interpretation
Summa Holdings Inc. v. Commissioner of Internal Revenue
Summa Holdings, Inc. v. Commissioner, 848 F.3d 779 (6th Cir. 2017)
Key Principle
The substance-over-form doctrine does not permit the IRS to recharacterize a transaction that uses a DISC and Roth IRA exactly as Congress designed those Code provisions to be used, because taxpayers are entitled to structure transactions to obtain tax benefits the statute deliberately confers.
Area of Law
General
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