On February 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Complex Media Inc. v. Commissioner (T.C. Memo. 2021-14). The primary issue presented in Complex Media Inc. v. Commissioner  was whether a taxpayer was eligible to disavow the form of its transactions (an asset transfer) when the alternative form achieves a tax benefit “not inconsistent” with the taxpayer’s initial tax planning and structuring of the transactions. Background to Complex Media Inc.