← All Authorities
United States 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)
JurisdictionUnited States
CourtUnited States Court of Appeals for the Sixth Circuit
Year2017
StatusBinding authority

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

Related Cases

Klein v. Martin 607 U. S. 213 (2026)
Ellingburg v. United States 607 U.S. ___ (2026)
Inc. v. Palmquist 607 U.S. 421 (2026)

Ask CommonBench about this case

Get a detailed analysis of Summa Holdings Inc. v. Commissioner of Internal Revenue and how it applies to your situation.

Explain Summa Holdings Inc. v. Commiss...