Laws, Regulations & Annotations
Property Taxes Law Guide – Revision 2015
Property Tax Annotations
220.0000 CHANGE IN OWNERSHIP
220.0666 Step Transaction. Whether a series of transfers constitute for tax purposes one or several transactions is a question of fact. The proper classification is made by application of three alternative court sanctioned tests, to wit: the
(a) binding commitment test,
(b) interdependence test, and
(c) end result test.
If at the time the first step is taken there was a binding commitment to take a later step(s), or if the first step would have been fruitless without the completion of the series, or if the ultimate or end result was intended from the outset, a conclusion that a series of transfers constituted a single transaction for "change of ownership" purposes is warranted. C 3/8/1990.