Kornfeld v. Commissioner

LOGAN, Circuit Judge.

This appeal presents the 'question whether the Tax Court correctly relied on the substance over form doctrine in determining that Julian P. Kornfeld (taxpayer) was not entitled to a federal income tax deduction for amortization of a life interest in bonds that he purportedly jointly purchased with his daughters and secretary, who took remainder interests.

The legal.right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid, them, by means which the law permits, cannot be doubt-ed____ But the question for determination is whether…