Frank Lyon Co. v. United States, 435 U.S. 561 (1978)

'In applying this doctrine of substance over form, the Court has looked to the objective economic realities of a transaction rather than to the particular form the parties employed. The Court has never regarded "the simple expedient of drawing up papers"... as controlling for tax purposes when the objective economic realities are to the contrary' (at 573) (quoting Commissioner v. Tower, 327 U.S. 280, 291 (1946), and citing Lazarus at 255 and Court Holding at 334).