OPINION
GIBBONS, Circuit Judge.
In 1986, petitioner-appellee Aeroquip-Vickers, Inc. (formerly known as Trinova Corporation, and operating as the Libbey-[175]*175Owens-Ford Company (LOF) at the time), transferred all of its assets relating to a glass manufacturing business, including property for which it had previously claimed investment tax credits (ITCs) under former 26 U.S.C. § 38 (Section 38 property), into a wholly-owned subsidiary, LOF Glass, Inc. (LOF Glass). LOF then transferred LOF Glass to one of its shareholders, Pilkington Holdings, in return for Pilkington Holdings’ shares in LOF. LOF treated this transaction as a corporate reorganization under 26 U.S.C. § 368(a)(1)(D) and accordingly did not recognize any gain or loss from the exchange on the consolidated federal income tax return for 1986 that it filed together with LOF Glass. LOF also did not report any recaptured ITCs from the transaction, as would be required by former 26 U.S.C. § 47(a)(1) upon the disposition of Section 38 property before the end of the property’s estimated useful life.
In 1993, the Commissioner of Internal Revenue (CIR) asserted a deficiency against LOF for LOF’s failure to include ITC recapture in income under former 26 U.S.C. § 47(a)(1) on its 1986 consolidated tax return. Trinova petitioned the United States Tax Court for a redetermination of the deficiency. The Tax Court held that neither the transfer of the property from LOF to LOF Glass nor the change in ownership of LOF Glass was a disposition of Section 38 property under 26 U.S.C. § 47, and that Trinova thus had no recapture obligations. CIR appealed. For the reasons set forth below, we reverse the decision of the Tax Court.
I.
The facts are not disputed. Pursuant to Tax Court Rule 91(a), the parties submitted a Stipulation of Facts, which the Tax Court summarized as follows:
Petitioner, an accrual basis taxpayer ... changed its name to Trinova from the Libbey-Owens-Ford Company (LOF) on July 31, 1986. Petitioner timely filed a consolidated Federal income tax return with certain of its subsidiaries for the years at issue with the Internal Revenue Service Center, Cincinnati, Ohio, or the Internal Revenue Service office in Toledo, Ohio. Petitioner was engaged in the fluid power and plastics businesses and the manufacture of glass. The- glass business was referred to as “LOF Glass Division.”
One of LOF’s largest shareholders was Pilkington Brothers (Pilkington), an English company, which owned 29 percent of petitioner’s common ■ stock through its wholly owned U.S. subsidiary, Pilkington Holdings, Inc. (Pilking-ton Holdings). Two of petitioner’s fourteen directors were associated with Pilkington. In late 1985, Pilkington approached LOF and began negotiations concerning the possibility of acquiring the glass business.
Earlier that year, on July 25, 1985, the board of directors of LOF approved the transfer of the glass business to a wholly owned subsidiary for valid business reasons. On February 19, 1986, LOF Glass, Inc. was incorporated as a wholly-owned subsidiary of LOF. On March 6, 1986, a “Transfer and Assumption Agreement,” amended on April 25, 1986, transferred to LOF Glass, Inc., all assets associated with the LOF Glass Division, including inventories and receivables, effective retroactively to February 19, 1986. These assets also included section 38 assets upon which LOF had previously claimed ITCs. Petitioner took no formal action contemplating the liquidation of LOF Glass, Inc., in the event that the acquisition by Pilking-ton did not take place.
[176]*176On March 7, 1986, LOF, Pilkington, and Pilkington Holdings entered into an agreement, amended on April 28, 1996, whereby LOF would transfer all of its shares of LOF Glass, Inc., to Pilkington Holdings in exchange for all of the shares of petitioner held by Pilkington Holdings. On April 28, 1996, Pilkington Holdings exchanged 4,064,550 shares of LOF for the shares of LOF Glass, Inc. LOF Glass, Inc., continued to operate the glass business as a subsidiary of Pilkington Holdings and used the section 38 assets in its trade or business.
The parties have stipulated that petitioner recognized no gain or loss upon the transaction whereby its glass business was transferred to LOF Glass, Inc., pursuant to the provisions of section 351 or sections 354, 355, and 368(a)(1)(D) (except as required by such sections or section 357(c)), and that pursuant to section 355 neither petitioner nor Pilking-ton Holdings recognized any gain or loss upon the exchange of LOF Glass, Inc., shares for the LOF shares.
Before February 19, 1986, income, deductions, and credits with respect to the LOF Glass Division were included in petitioner’s return. From February 19, 1986, through April 28, 1986, deductions and credits with respect to LOF Glass, Inc. (the subsidiary), were included as part of petitioner’s consolidated return. After April 28, 1986, LOF Glass, Inc., was no longer part of petitioner, petitioner’s affiliated group, or petitioner’s consolidated Federal income tax return.
On its 1986 consolidated return, petitioner did not include any amount of ITC recapture with respect to the LOF Glass, Inc., section 38 assets. Respondent determined that a $5,718,749 ITC recapture arose from the April 1986 transaction. Petitioner does not dispute the amount of the ITC recapture....
On November 26, 1993, CIR issued a notice of deficiency to Trinova, stating that Trinova had understated its tax liabilities on the consolidated income tax returns that it had filed with its subsidiaries between 1985 and 1988. On February 18, 1994, Trinova filed a petition with the Tax Court contesting the deficiencies, including CIR’s recapture of ITCs under 26 U.S.C. § 46. On February 27, 1997, the Tax Court found in favor- of Trinova on the issue of the recapture of the ITCs. On October 1, 2001, the Tax Court entered a decision disposing of all claims of all parties. CIR timely filed a notice of appeal.
II.
The Tax Court’s application of law to the fully stipulated record is reviewed de novo. See Friedman v. Comm’r, 216 F.3d 537, 541 (6th Cir.2000).
Under former 26 U.S.C. §§ 38 and 46, a taxpayer who acquired certain machinery and equipment for use in its trade or business (Section 38 property) was allowed a credit against its income tax liability in an amount equal to a percentage of his investment (the ITC). However, under former 26 U.S.C. § 47, the ITC was limited to property that the taxpayer used in its trade or business for most of the property’s useful life. If the taxpayer disposed of Section 38 property before the end of the useful life, then the taxpayer was required to recapture the ITC and increase its tax liability. See 26 U.S.C. § 47(a)(1). The stated purpose of this provision was “[t]o guard against a quick turnover of assets by those seeking multiple credit.” S.Rep. No. 1881, 87th Cong., 2d Sess. 11 (1962), U.S. Code Cong. & Admin. News at 3297, 3320.
Determining that Trinova was not liable for ITC recapture, the Tax Court emphasized that “the transactions herein took place in the consolidated return context.” [177]*177Section 1.1502-3(f)(2)(i) of the Consolidated Return Regulations (CRR) states that “a transfer of section 38 property from one member of the group to another member of such group during a consolidated return year shall not be treated as a disposition or cessation within the meaning of section 47(a)(1).” Defending the Tax Court’s application of this provision to the facts in this case, Aeroquip-Vickers observes that “[a]f-ter [LOF] transferred the LOF Glass Division business ... to LOF Glass including some section 38 property, LOF Glass continued to use the section 38 property while a member of the [LOF] affiliated group,” and thus asserts that the “transfer of the section 38 property to LOF Glass ... was a non-event under section 47; there was no ‘disposition’ of section 38 property.” In addition, Aeroquip-Vickers argues that “this non-event for section 37 purposes did not metamorphose into an ITC recapture event merely because LOF glass ultimately left the [LOF] affiliated group” since “LOF Glass continued to use the section 38 property up to and following the time that LOF Glass left the [LOF] affiliated group.” Aeroquip-Vickers thus claims that “there would be no recapture event unless or until LOF Glass disposed of the section 38 property.” (emphasis in brief).
In support of its decision, the Tax Court relied upon CRR § 1.1502-3(0(3), which provides the following examples:
Example (1). P, S, and T file a consolidated return for calendar year 1967. In such year S places in service section 38 property having an estimated useful life of more than 8 years. In 1968, P, S, and T file a consolidated return and in such year S sells such property to T. Such sale will not cause section 47(a)(1) to apply.
Example (3). Assume the same facts as in example (1), except that P, S, and T continue to file consolidated returns through 1971 and in such year T disposes of the property to individual A. Section 47(a)(1) will apply to the group ...
Example (5). Assume the same facts as in example (1), except that in 1969, P sells all the stock of T to a third party. Such sale will not cause section 47(a)(1) to apply. [178]*178When there is no intention at the time of transfer to keep the property within the consolidated group, the transaction should be viewed as a whole and not as separate individual transactions.... Because the transfer of the section 38 property from P to S is a step in the planned transfer of the property outside the group, the exception in section 1.1502 — 3(f)(2)(i) of the regulations does not apply to this transaction. Therefore, the transfer from P to S is a disposition under section 47(a)(1) of the Code.
[177]*177The Tax Court first noted that “the mere transfer of section 38 assets within a consolidated group does not trigger recapture” and then added that Example 5 illustrated that “the transfer of the stock of [LOF" Glass] to Pilkington Holdings would not trigger the recapture of such credit.” Trinova Corp. v. Commissioner, 108 T.C. 68, 73, 1997 WL 90362 (1997) (emphasis added).
CIR argues that the Tax Court erred by failing to give appropriate deference to Revenue Ruling 82-20, 1982 WL 199022. Revenue rulings are official interpretations by the IRS which have been published in the Internal Revenue Bulletin. 26 CFR § 601.201(a)(6). Under the facts assumed by' Revenue Ruling 82-20, parent corporation P owns 100 percent of subsidiary corporation S. P and S file a consolidated federal income tax return. A and B, equal owners of P, decide to split the business into two independent corporations, one owned by A and the other owned by B. To achieve this, “P transferred all the assets of one of the businesses necessary to conduct the trade or business, including section 38 property, to S solely in exchange for additional shares in S and immediately thereafter distributed all the stock of S to A.... A surrendered all its stock in P as part of the transaction.” Id. Revenue Ruling 82-20 states that:
[178]*178
Id.
Rejecting CIR’s position, the Tax Court concluded that “Example 5 and not Rev. Rui. 82-20 ... provides the key to decision herein.” Trinova Corp. v. Comm’r, 108 T.C. 68, 77, 1997 WL 90362 (1997). The Tax Court acknowledged that both the Second Circuit in Salomon Inc. v. United States, 976 F.2d 837 (2d Cir.1992) and the Ninth Circuit in Walt Disney Inc. v. Comm’r, 4 F.3d 735 (9th Cir.1993), cases involving “factual situation[s] substantially similar to that involved herein,” had reached the opposite conclusion. However, the Tax Court explained that
[w]ith all due respect, we disagree with both the result and the reasoning of the Courts of Appeals.... We think that the fact that the transfer of the assets and the transfer of the stock occurred in the same, rather than different, taxable years does not provide a meaningful basis for distinguishing Rev. Rui. 82-20 ... from Example 5 of the regulations .... We think the Courts of Appeals for the Second and Ninth Circuits accorded the ruling undue weight and that revenue rulings play a lesser role than the language of the opinions of those Courts of Appeals seems to indicate.
Trinova Corp., 108 T.C. at 76-77. The Tax Court also added that in this case CIR “has stipulated that there was a business purpose, i.e. substance, to the transfer by petitioner to [LOF Glass].” Id. at 78.
In Salomon, Engelhard Minerals and Chemicals Corporation (EMC) (later known as Salomon) developed a plan to separate its marketing arm and its industrial divisions into two independent companies. 976 F.2d at 838. EMC transferred the assets and liabilities of its industrial divisions to Porocel, an existing wholly owned subsidiary (later renamed Engel-hard Corporation (EC)). Id. In return, EMC received EC stock. Id. Four days later, EMC “[spun] off’ EC “by distributing all of its EC shares pro-rata to its stockholders.” Id. The IRS determined that EMC would not recognize gain as a result of the transaction. Id. at 839. However, the IRS also noted that “[c]er-tain of the machinery, equipment and other assets that EMC planned to transfer to EC qualified as section 38 property,” and concluded that the “transfer of this property to EC followed by a spin-off to EMC shareholders [was] a ‘disposition’ which triggered § 47(a) recapture.” Id. at 840. Salomon brought suit to recover the recapture taxes paid. Id.
The Second Circuit concluded that Revenue Ruling 82-20 was not “unreasonable, nor inconsistent with prevailing law,” and thus was “entitled to great deference.” Id. at 841. The Second Circuit explained that since a direct transfer of Section 38 property was a disposition under 26 U.S.C. § 47(a)(1), “the more circuitous transfer by way of another consolidated group member should be as well.” Id. at 842.
In substance, if not in form, the direct and the circuitous transaction are the same. Each achieves a rapid transfer of section 38 property outside the group. To distinguish between them would deny economic reality. Moreover, such a holding would allow the common parent [179]*179of a consolidated group, such as EMC, to move section 38 property outside the group without paying recapture taxes simply by first transferring the property to a member subsidiary and then distributing the subsidiary’s stock to the third-party. Revenue Ruling 82-20’s requirement of recapture under these circumstances is not unreasonable.
The rapidity with which these components follow one another suggest that they are, in substance, parts of one overall transaction intended to dispose of the section 38 assets outside of the consolidated group. Revenue Ruling 82-20 further solidifies this inference by positing that there is “no intention at the time of transfer to keep the property within the consolidated group.” These factual circumstances, timing and intent, differ from those presented in CRR Example 5. They lead to the conclusion that the two components are steps in a larger transaction which, when viewed as a whole, constitutes a § 47(a)(1) “disposition.”
Id. at 842 (citations omitted).
The reasoning and conclusion of the Second Circuit was subsequently adopted by the Ninth Circuit in Walt Disney. In that case, Retlaw, a predecessor of Walt Disney Inc. (Disney), developed a plan to separate its “Disney assets” (including the commercial rights to the name “Walt Disney” and two attractions at Disneyland) from its “non-Disney assets” (two television stations, a cattle ranch, and several agricultural properties), and then allow Walt Disney Productions (Productions) to acquire Retlaw (which would only retain its Disney assets). Walt Disney, 4 F.3d at 737. In order to accomplish this, Retlaw transferred its non-Disney assets, which included Section 38 property, to a newly-formed, wholly owned subsidiary called Flower Street. Id. In exchange, Retlaw received Flower Street common stock. Id. That same day, the Retlaw board of directors authorized the distribution of the Flower Street stock pro rata to the Retlaw shareholders, but specified that the distribution could only be made concurrently with the closing of Productions’ proposed acquisition of Retlaw. Id. The actual distribution occurred fifty-nine days later, immediately following the approval of the Retlaw acquisition by Productions’ shareholders and just prior to Productions’ acquisition of the stock of Retlaw. Id. at 738.
Retlaw and Flower Street then filed a consolidated federal income tax return. Id. In the consolidated return, however, Retlaw did not recapture the ITCs it previously had taken on Section 38 property included among the non-Disney assets transferred to Flower Street. Id. As a result, the IRS assessed a deficiency, which Disney contested. Id. Reversing the decision of the Tax Court, the Ninth Circuit applied Revenue Ruling 82-20 and determined that Disney was required to recapture the ITC it had previously taken with respect to Section 38 property transferred by Retlaw to Flower Street. Id. at 739. The Ninth Circuit explained that
Revenue Ruling 82-20 is not unreasonable because “[i]n substance, if not in form, the direct and the circuitous transaction are the same” and “to distinguish between them would deny economic reality” and would allow the common parent of a consolidated group to circumvent easily the recapture requirement. Moreover, Revenue Ruling 82-20 and Example 5 of the Consolidated Return Regulations are not inconsistent because they address different situations: the latter covers situations where, due to a “meaningful time delay” between the asset transfer and the spin-off, there is [180]*180“little reason to believe that the trans-feror corporation intends to use the transaction as a means of moving section 38 property out of the group while avoiding recapture taxes”; the former involves facts under which the transfer- or’s initial intent to move section 38 property out of the consolidated group is undisputed.
Id. (quoting Salomon, 976 F.2d at 842) (internal citations omitted).
As the Tax Court observed, both the Second Circuit and the Ninth Circuit afforded “great deference” to Revenue Ruling 82-20. This court previously has held that “[although a revenue ruling ‘is not entitled to the deference accorded a statute or a Treasury Regulation,’ a revenue ruling is entitled to some deference unless ‘it conflicts with the statute it supposedly interprets or with that statute’s legislative history or if it is otherwise unreasonable.’ ” CenTra, Inc. v. United States, 953 F.2d 1051, 1056 (6th Cir.1992) (quoting Threlkeld v. Comm’r, 848 F.2d 81, 84 (6th Cir.1988)); see also Johnson City Med. Ctr. v. United States, 999 F.2d 973, 977 (6th Cir.1993) (“[T]his Court accords deference to Revenue Ruling 85-74 under the standard set forth in Chevron [U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842-43, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984)].”1); Wuebker v. Comm’r, 205 F.3d 897, 903 (6th Cir.2000).
However, recent Supreme Court decisions limiting the Chevron doctrine have called our earlier cases into question. In Christensen v. Harris County, 529 U.S. 576, 587, 120 S.Ct. 1655, 146 L.Ed.2d 621 (2000), the Supreme Court held that “[i]n-terpretations such as those in opinion letters — like interpretations contained in policy statements, agency manuals, and enforcement guidelines, all of which lack the force of law — do not warrant Chevron-style deference.” The Court explained that such agency interpretations are entitled to respect, “but only to the extent that those interpretations have the ‘power to persuade.’ ” Id. (quoting Skidmore v. Swift & Co., 323 U.S. 134, 140, 65 S.Ct. 161, 89 L.Ed. 124 (1944)). In United States v. Mead Corp., 533 U.S. 218, 226-27, 121 S.Ct. 2164, 150 L.Ed.2d 292 (2001), the Supreme Court emphasized that Chevron deference is appropriate only “when it appears that Congress delegated authority to the agency generally to make rules carrying the force of law, and that the agency interpretation claiming deference was promulgated in the exercise of that authority” through “notice- and-comment rulemaking, or by some other indication of a comparable congressional intent.” The Court added that “an agency’s interpretation may merit some deference whatever its form, given the ‘specialized experience and broader investigations and information’ available to the agency, and given the value of uniformity in its administrative and judicial understandings of what a national law requires.” Id. at 234, 121 S.Ct. 2164 (quoting Skidmore, 323 U.S. at 139-40, 65 S.Ct. 161). In United States v. Cleveland Indians Baseball Co., 532 U.S. 200, 220, 121 S.Ct. 1433, 149 L.Ed.2d 401 (2001), the Supreme Court declined to consider “whether the Revenue Rulings themselves are entitled to deference.” However, the Court noted that the revenue rulings at [181]*181issue “reflect the agency’s longstanding interpretation of its own regulations,” and concluded that “[bjecause that interpretation is reasonable, it attracts substantial judicial deference.” Id.
When promulgating revenue rulings, the IRS does not invoke its authority to make rules with the force of law. Specifically, the IRS does not claim for revenue rulings “the force and effect of Treasury Department regulations.” Rev. Proc. 89-14, 1989-1 C.B. 814, 1989 WL 519042. In light of the Supreme Court’s decisions in Christensen and Mead, we conclude that Revenue Ruling 82-20 should not be accorded Chevron deference. Revenue rulings do, however, constitute “precedents to be used in the disposition of other cases.” Rev. Proc. 89-14, 1989-1 C.B. 815. Revenue rulings also serve as “official interpretation[s]” by the IRS of the tax laws. Treas. Reg. § 601.201(a)(6). By noting only that revenue rulings “are not entitled to the deference accorded a statute or a Treasury Regulation,” without explicitly acknowledging that some deference to revenue rulings is proper, the Tax Court mischaracterized the degree of deference accorded to revenue rulings. See, e.g., Omohundro v. United States, 300 F.3d 1065, 1069 (9th Cir.2002) (granting Skidmore deference to a revenue ruling); Del Commercial Props., Inc. v. Comm’r, 251 F.3d 210, 214 (D.C.Cir.2001) (same); U.S. Freightways Corp. v. Comm’r, 270 F.3d 1137, 1142 (7th Cir.2001) (same); American Express Co. v. United States, 262 F.3d 1376, 1383 (Fed.Cir.2001) (reasoning that “[i]n the context of tax cases, the IRS’s reasonable interpretations of its own regulations and procedures are entitled to particular deference.” (citing Cleveland Indians, 532 U.S. at 220, 121 S.Ct. 1433)).2 Consequently, the level of deference to be accorded to Revenue Ruling 82-20 depends upon “the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control.” Mead, 533 U.S. at 228, 121 S.Ct. 2164 (quoting Skidmore, 323 U.S. at 140, 65 S.Ct. 161). Consideration of all of these factors leads us to conclude that some deference to Revenue Rule 82-20 is proper.3
Aeroquip-Vickers argues that “neither the ITC regime nor the consolidated return regulations contain any ambiguity justifying Rev. Rui. 82-20.” Aeroquip-Vickers further contends that Revenue Ruling 82-20 is inconsistent with § 1.1502 3(f) because the express terms of § 1.1502-3(f) do not explicitly refer to “intent” or “timing” requirements. As previously discussed, substantially similar challenges to Revenue Ruling 82-20 were considered and rejected by both the Second and Ninth Circuits in Salomon and Walt Disney. “Uniformity among the circuits is especially important in tax cases to ensure equal and certain administration of the tax system. We would therefore hesitate to reject the view of another circuit.” Nickell v. Comm’r, 831 F.2d 1265, 1270 (6th Cir.1987).
Moreover, the approach favored by CIR and adopted by the Second and Ninth [182]*182Circuits is entirely reasonable. Example 5 of CRR § 1.1502 — 3(f) involves a situation where the asset transfer occurs in one year and the spin-off takes place in the following year, while Revenue Ruling 82-20 applies to situations where (as in the instant case) the asset transfer is “immediately” followed by the spin-off. Whether the use of different years “merely illustrate[s] the sequence of events,” as Aero-quip-Viekers argues, or rather signifies a “meaningful time delay” between the two steps, Salomon, 976 F.2d at 842, is an extremely close question. However, the more persuasive interpretation is that the decision to assign different events to different calender years in Example 5 of CRR § 1.1502—3(f), rather than merely listing the order of events, has greater significance. See 2A Singer, Norman J., Sutherland Statutes and Statutory Construction, § 46.06 at 192 (2000 ed.) (“every word of a statute must be presumed to have been used for a purpose”). Consequently, we conclude that the underlying rationale of Revenue Ruling 82-20 is valid, “reflects] the agency’s longstanding interpretation of its own regulations,” and thus deserves “substantial judicial deference.” Cleveland Indians Baseball Co., 532 US. at 220, 121 S.Ct. 1433.
Aeroquip-Vickers also argues that the “step transaction doctrine” is inapplicable in this case, since CIR has stipulated that valid business reasons existed for the intermediate steps taken by LOF. The step-transaction doctrine was not directly addressed in either Salomon or Disney. However, as Judge Swift of the Tax Court observed in his dissenting opinion, both of those decisions “rel[ied] heavily on ‘economic reality’ and the ‘substance-over-form’ doctrines, which are simply broader labels for, and which encompass, the step transaction doctrine.” Trinova Corp. v. Commissioner, 108 T.C. 68, 79, 1997 WL 90362 (1997) (Swift, J., dissenting). When analyzing the question of whether the separate steps of a complex transaction should be treated as having independent significance or as related steps in a unified transaction, “courts have enunciated a variety of doctrines, such as step transaction, business purpose, and substance over form. Although the various doctrines overlap and it is not always clear in a particular case which one is most appropriate, their common premise is that the substantive realities of a transaction determine its tax consequences.” King Ent. Inc. v. United States, 189 Ct.Cl. 466, 418 F.2d 511, 516 n. 6 (1969); see also Comm’r v. Court Holding Co., 324 U.S. 331, 334, 65 S.Ct. 707, 89 L.Ed. 981 (1945) (“The incidence of taxation depends upon the substance of a transaction.”); Brown v. United States, 782 F.2d 559, 563 (6th Cir.1986) (“The step transaction doctrine is a judicial device expressing the familiar principle that in applying the income tax laws, the substance rather than the form of the transaction is controlling.”) (quotation omitted).
This court has applied the “end result” test in order to determine whether the steps of a transaction should be treated separately or as a single unit. Brown, 782 F.2d at 563-564. “Under that test, purportedly separate transactions will be amalgamated into a single transaction when it appears that they were really component parts of a single transaction intended from the outset to be taken for the purpose of reaching the ultimate result.” Id. at 564 (quotations omitted) (emphasis added).
A recitation of the stipulated facts supports the conclusion that LOF entered the transaction with the intent to move Section 38 property out of the consolidated group. In late 1985 representatives of Pilkington approached LOF concerning the possibility of acquiring its glass business. Negotia[183]*183tions concerning this transaction took place between November 1985 and March 1986. LOF’s transfer of its glass business and its Section 38 property to LOF Glass occurred on March 6,1986. One day later, LOF, Pilkington, and Pilkington Holdings entered into an agreement providing that LOF would transfer all of its interest in LOF Glass to Pilkington Holdings in exchange for Pilkington Holdings’ entire interest in LOF. On April 28, 1986, Pilking-ton exchanged shares of LOF for the shares of LOF Glass. After that date, LOF Glass was no longer part of LOF’s affiliated group, nor was it part of LOF’s consolidated federal income tax return. From the beginning, an intent on the part of LOF to move Section 38 property out of the consolidated group without paying recapture taxes by first transferring the property to LOF Glass and then distributing LOF Glass’s stock to Pilkington is evident.
Aeroquip-Vickers argues that, unlike in Disney and Salomon, in this case CIR “stipulated to the propriety not only of each step but also of the entire reorganization and split-off.” Aeroquip-Vickers contends that since “the whole transaction and each step along the way had economic substance,” no “tax avoidance motive” can be attributed to LOF.
Admittedly, this case does not involve a situation where “[t]he whole undertaking ... was in fact an elaborate and devious form of conveyance masquerading as a corporate reorganization, and nothing else.” Gregory v. Helvering, 293 U.S. 465, 470, 55 S.Ct. 266, 79 L.Ed. 596 (1935) (emphasis added). Aeroquip-Vickers correctly notes that CIR has stipulated that the requirements of 26 U.S.C. § 368(a)(1)(D) were met in this case. The individual steps of the transaction had a valid business purpose. However, “[t]he law is unclear as to the relationship between the step transaction doctrine and the business purpose requirement. Our survey of the relevant cases suggests that no firm line delineates the boundary between the two.”' Associated Wholesale Grocers, Inc. v. United States, 927 F.2d 1517, 1526 (10th Cir.1991). In Associated Wholesale Grocers, the Tenth Circuit held that the existence of a valid business purpose does not preclude application of the step transaction doctrine, explaining that “ ‘[a] legitimate business goal does not grant [a] taxpayer carte blanche to subvert Congressionally mandated tax patterns.’ ” Id. at 1527 (quoting Kuper v. Comm’r, 533 F.2d 152, 158 (5th Cir.1976)). The substance over form inquiry thus is not as narrow as Aeroquip-Vickers suggests.
Here, although the individual steps of the transaction had a legitimate business reason, the transaction must be treated as a single unit and judged by its end result. “To ratify a step transaction that exalts form over substance merely because the taxpayer can either (1) articulate some business purpose allegedly motivating the indirect nature of the transaction or (2) point to an economic effect resulting from the series of steps, would frequently defeat the purpose of the substance over form principle.” True v. United States, 190 F.3d 1165, 1177 (10th Cir.1999). Aeroquip-Vickers has shown only the existence of a non-tax business purpose for engaging in a series of transactional steps “to accomplish a result [it] could have achieved by more direct means.” Id. (quoting Associated Wholesale Grocers, 927 F.2d at 1527). Notwithstanding this business purpose, CIR correctly concluded that the intended end result of the transaction was to allow LOF to avoid liability for ITC recapture.
III.
For the foregoing reasons, we reverse the decision of the Tax Court.