submitted a claim arising as a result of a general default and Voyager denied the claim. Your Credit might then argue that the policy should be reformed because the parties intended to write a general default policy, although the policy, as actually written, covered losses due solely to Your Credit’s failure to file a financing statement. Edwards, however, contends that Your Credit and Voyager deliberately structured the form of the policy in stark contrast to its substance to take advantage of consumers for their mutual benefit. Such an argument is akin to the substance-over-form doctrine in tax law in which we look past the labels the parties give to a structure to determine its economic reality. See Gregory v. Helvering, 293 U.S. 465, 469, 55 S.Ct. 266, 267, 79 L.Ed. 596 (1935) (<HOLDING>); Waterman S.S. Corp. v. Commissioner, 430 F.2d
holding that a transaction disregarded for lack of economic substance  a nonvaluationrelated ground  nevertheless may be subject to a valuation misstatement penalty because a transaction that lacks economic substance generally reflects an arrangement in which the basis of the property was misvalued in the context of the transaction and that congress intended to penalize such transactions recognizing that a transaction that lacks economic substance generally reflects an arrangement in which the basis of the property was misvalued in the context of the transaction holding nature of motion is determined by its substance not its title recognizing step transaction doctrine whereby courts must consider all steps of transaction in light of entire transaction so that substance of transaction will control over form of each step holding that the economic substance of a transaction rather than its form determines its tax treatment