Courts typically scrutinize transactions between related parties. They will often use different descriptions for the type of scrutiny that they are applying. For example, some courts will say that they are applying “careful” scrutiny, while others will indicate “close” or “extra” scrutiny. Other descriptions include: “heightened,” “rigid,” “special,” or “strict” scrutiny. These terms seem to be used interchangeably. Below are excerpts from some tax cases using these terms. Beretta v. Commr., T.C. Memo 1997-570: Courts... Read more →