step transaction doctrine
E302258
The step transaction doctrine is a U.S. tax law principle that collapses formally separate but related steps into a single integrated transaction to determine their true tax consequences.
All labels observed (1)
| Label | Occurrences |
|---|---|
| step transaction doctrine canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2830227 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: step transaction doctrine Context triple: [Helvering v. Gregory, relatedDoctrine, step transaction doctrine]
-
A.
Noerr-Pennington doctrine
The Noerr-Pennington doctrine is a U.S. legal principle that shields individuals and entities from antitrust liability when they petition the government, even if their efforts have anticompetitive effects.
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B.
substantial effects doctrine
The substantial effects doctrine is a constitutional law principle allowing Congress to regulate even local, non-commercial activity under the Commerce Clause if, in the aggregate, it exerts a substantial effect on interstate commerce.
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C.
Clifford trust doctrine
The Clifford trust doctrine is a U.S. tax law principle that treats certain short-term or highly controlled trusts as effectively owned by the grantor, causing the trust’s income to be taxed to that grantor.
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D.
Regulation T
Regulation T is a Federal Reserve Board rule that governs the extension of credit by securities brokers and dealers, including margin requirements for purchasing securities.
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E.
Sanctuary doctrine
The Sanctuary doctrine is a distinctive Seventh-day Adventist teaching that interprets Christ’s ongoing heavenly ministry and the investigative judgment through the symbolism of the Old Testament sanctuary services.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: step transaction doctrine Target entity description: The step transaction doctrine is a U.S. tax law principle that collapses formally separate but related steps into a single integrated transaction to determine their true tax consequences.
-
A.
Noerr-Pennington doctrine
The Noerr-Pennington doctrine is a U.S. legal principle that shields individuals and entities from antitrust liability when they petition the government, even if their efforts have anticompetitive effects.
-
B.
substantial effects doctrine
The substantial effects doctrine is a constitutional law principle allowing Congress to regulate even local, non-commercial activity under the Commerce Clause if, in the aggregate, it exerts a substantial effect on interstate commerce.
-
C.
Clifford trust doctrine
The Clifford trust doctrine is a U.S. tax law principle that treats certain short-term or highly controlled trusts as effectively owned by the grantor, causing the trust’s income to be taxed to that grantor.
-
D.
Regulation T
Regulation T is a Federal Reserve Board rule that governs the extension of credit by securities brokers and dealers, including margin requirements for purchasing securities.
-
E.
Sanctuary doctrine
The Sanctuary doctrine is a distinctive Seventh-day Adventist teaching that interprets Christ’s ongoing heavenly ministry and the investigative judgment through the symbolism of the Old Testament sanctuary services.
- F. None of above. chosen
Statements (49)
| Predicate | Object |
|---|---|
| instanceOf |
U.S. tax law doctrine
ⓘ
judicial anti-avoidance doctrine ⓘ |
| appliedBy |
Internal Revenue Service
ⓘ
United States Tax Court ⓘ
surface form:
U.S. Tax Court
federal appellate courts ⓘ |
| appliesInJurisdiction |
United States of America
ⓘ
surface form:
United States
|
| appliesTo |
basis step-up planning
ⓘ
disguised sales in partnerships ⓘ divisive reorganizations ⓘ estate freeze transactions ⓘ like-kind exchanges ⓘ stock and asset acquisitions ⓘ tax-free corporate reorganizations ⓘ |
| basedOnPrinciple |
substance over form
ⓘ
tax avoidance prevention ⓘ |
| bindingCommitmentTestDefinition | collapses steps when there is a binding obligation to complete later steps ⓘ |
| consequenceOfApplication |
disallowance of claimed tax benefits
ⓘ
possible recognition of gain or loss earlier than planned ⓘ recharacterization of transaction for tax purposes ⓘ |
| coreIdea |
collapses multiple formally separate steps into a single transaction
ⓘ
determines tax consequences based on integrated transaction ⓘ |
| endResultTestDefinition | collapses steps undertaken to achieve a particular ultimate result ⓘ |
| fieldOfUse |
corporate tax
ⓘ
estate and gift tax ⓘ federal income tax ⓘ partnership tax ⓘ reorganization tax ⓘ |
| focusesOn |
objective relationship of steps
ⓘ
taxpayer intent and plan ⓘ |
| goal |
determine true tax consequences of integrated transactions
ⓘ
prevent manipulation of transactional form ⓘ |
| interdependenceTestDefinition | collapses steps that are meaningless unless all occur ⓘ |
| legalSystem | common law ⓘ |
| relatedConcept |
business purpose doctrine
ⓘ
economic substance doctrine ⓘ sham transaction doctrine ⓘ substance over form doctrine ⓘ |
| requires |
series of formally separate steps
ⓘ
sufficient relationship among steps ⓘ |
| sourceOfLaw |
case law
ⓘ
judicial interpretation of the Internal Revenue Code ⓘ |
| test |
binding commitment test
ⓘ
end result test ⓘ interdependence test ⓘ |
| typicalContext |
prearranged sale or exchange transactions
ⓘ
tax-motivated multi-step restructuring ⓘ |
| usedTo |
deny unintended tax benefits
ⓘ
identify abusive tax-motivated structuring ⓘ recharacterize multi-step transactions ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: step transaction doctrine Description of subject: The step transaction doctrine is a U.S. tax law principle that collapses formally separate but related steps into a single integrated transaction to determine their true tax consequences.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.