26 U.S.C. § 9722
Section 9722 · Sham transactions
Amended 1 time on record
Applied in 6 court decisions — leading case United States v. Workinger (1996)
Most recently applied in Michael Holland v. Westmoreland Coal Compan (August 2020)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
If a principal purpose of any transaction is to evade or avoid liability under this chapter, this chapter shall be applied (and such liability shall be imposed) without regard to such transaction.