Canal Corporation & Subsidiaries v. Commissioner, 135 TC 199, Code Sec(s) 707; 752.

CANAL CORPORATION & SUBSIDIARIES, FORMERLY CHESAPEAKE CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Case Information:

135 T.C. No. 9

(READ THE ABOVE CASE TO ANSWER THE FOLLOWING QUESTIONS)

1. Explain your understanding of each of the two following terms and give an example from the case where Chesapeake violated each of these doctrines to arrive at the results it wanted (use any resource to learn more about what each term means: tax books, Google, Bing, etc. they are similar but different as well):

a. Step transaction doctrine

b. Substance over form

2. Explain at least two ways Chesapeake sabotaged its own tax position in 1999 on its tax return and/or financial statements (from the court case).

a. What could they have done differently to strengthen its arguments that this entire transaction was not merely tax avoidance with no business purpose?

3. What happened with PwC as part of this transaction?

a. Do you think the partners were aware of the position they were putting their firm in by the manner in which they structured their engagement?

b. What could PwC have done differently to remove the perceived bias towards its client?