A taxpayer, like the Internal Revenue Service, may argue that the form of a transaction is different from its substance, and that the substance should govern the tax consequences of the transaction. Since the form is typically specified by documents drafted with the participation of the taxpayer, courts have developed doctrines that often dismiss substance-over-form arguments made by taxpayers. In Complex Media v. Commissioner (T.C. Memo 2021-14), however, a corporate taxpayer that acquired a business in exchange for stock and other property prevailed over the IRS, on the basis of an argument that the substance of the transaction was different from its form, and was allowed to claim amortization deductions attributable to a basis step-up arising from the substance of the transaction.