what Maxim was applied to reduce the tax,

Generate income in a lower tax rate entity - tax costs decrease

 what doctrine the court referenced to deny the tax strategy, and the Internal Revenue Code sections cited.

After reading chapters 3, 4, and 5 "PRINCIPLES OF TAXATION FOR BUSINESS AND INVESTMENT PLANNING, 25TH EDITION BY: SALLY JONES, 

 

conduct tax research to find a relevant tax court (or Appeals Court or US Supreme Court) case. Summarize the tax case, 

US Tax laws are based on several important doctrines.

• The assignment of income doctrine - states that income must be taxed to the entity that renders the service or owns the capital with respect to which the income is paid.
• The economic substance doctrine - holds that a transaction thatchanges the taxpayer's economic situation only for the tax savings from the transaction can be disregarded by the IRS.
• The business purpose doctrine- a transaction should not be effective or allowed for tax purposes unless it has a business purpose other than tax avoidance.
• The step transaction doctrine - allows the IRS to collapse a series of intermediate transactions into a single transaction to determine the tax consequences of the arrangement in its entirety.

To perform professional tax planning, we adhere to several maxims. First, we need to analyze the variables that determine the tax consequences of a transaction. Then we apply one or more of the following tax planning maxim strategies that reduce tax and enhance cash flows:

• .
• Defer taxes - shift income to a future year when rates are lower or move expenses forward to the current year when tax rates are higher or they can decrease income.
• Generate income in a lower tax jurisdiction - tax costs decreasewhen income is taxed at a lower tax rate.
• Change the character of the revenue - tax costs decreasewhen income is taxed at a preferential rate because of its character.

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The doctrine referenced to deny the tax strategy of generating income in a lower tax rate entity is ... View the full answer