Delpher Trades Co. vs. IAC

Tax Avoidance; The legal right of a taxpayer to decrease the amount of what otherwise could be his taxes or altogether avoid them, by means which the law permits, cannot be doubted. — The conveyance of property to a family corporation for shares do not point to anything wrong or objectionable about this “estate planning” scheme resorted to by the owners of the property. The “Deed of Exchange” of property between the Pachecos and Delpher Trades Corporation cannot be considered a contract of sale. There was no transfer of actual ownership interests by the Pachecos to a third party. The Pacheco family merely changed their ownership from one form to another. “The legal right of a taxpayer to decrease the amount of what otherwise could be his taxes or altogether avoid them, by means which the law permits, cannot be doubted.”