Integration of multiple payments or events into a single transaction can favor a taxpayer or the fisc, depending on the circumstances. In GSS Holdings (Liberty) Inc. v. United States, 128 AFTR 2d 2021-5333, the Court of Federal Claims recently integrated multiple events into a single transaction and then disallowed the resulting loss, because it viewed the integrated transaction as a sale by a partnership to a related party. A corporate partner in that partnership that sought a better tax result through reporting the events in a different manner on an amended tax return of its own failed to persuade the court that a loss should be allowed. More helpfully, however, at least as precedent for other taxpayers, the court rejected the argument of the government that the doctrine of Commissioner v. Danielson, 378 F.2d 771 (3d Cir. 1967) bound each partner to follow the characterization of the events reflected by the partnership on its original tax return.