"[T]he solution of hard tax cases requires something more than the easy generalization that the substance rather than the form of a transaction is determinative of its tax effect. * * * [I]n numerous situations the form by which a transaction is effected does influence or control its tax consequences * * *."
Casner v. Commr., 450 F.2d 379 (5th Cir. 1971)
"The statute itself exalts form over substance."
Chrome Plate, Inc. v. Commr., 614 F.2d 990 (5th Cir. 1980)