Without evidence to the contrary, the IRS views transactions occurring within one year of a reorganization as part of the restructuring under the step transaction doctrine.

Question

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The IRS often applies the step transaction doctrine to treat a series of formally separate steps as a single transaction if they are in substance integrated, interdependent, and focused toward a particular result. This approach can include transactions occurring within one year of a reorganization, viewing them as part of the restructuring process unless evidence suggests otherwise.

Without Evidence to the Contrary, the IRS Views Transactions Occurring