Taxpayers are not required to continue that form of organization which results in the maximum tax.
--Raymond Pearson Motor Company v. Commissioner, 246 F.2d 509 (1957)
Whether the purpose be to gain an advantage under the law of the state of incorporation or to avoid or to comply with the demands of creditors or to serve the creator's personal or undisclosed convenience, so long as that purpose is the equivalent of business activity or is followed by the carrying on of business by the corporation, the corporation remains a separate taxable entity.
--Moline Properties v. Commissioner of Internal Revenue, 319 U.S. 436 (1943)