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were going to be talking about / forum doctrine substance form doctrine the point is that the substance of a transaction and not necessarily the form of it will be the determining factor about the tax treatment and the tax consequences so a substance and not the form will determine the tax treatment and when I give you some examples itll make that a little bit clearer now we previously talked about sham transactions and sham events and sham entities these difference the substance over form is different because by definition with substance over form there is some economic substance to this so these are transactions that do have economic substance so theyre not shams but there can be confusion now when we understand the doctrine and to understand some examples the doctrine attributes the transaction and Im going to read this for you the doctrine attributes the transaction to the taxpayer who receives the economic substance the doctrine attributes the transaction to the taxpayer who r