liability, and it lacked any reasonable probability of generating a profit. We review de novo the tax court’s “general characterization of a transaction for tax purposes.” Frank Lyon Co. v. United States, 435 U.S. 561, 581 n. 16, 98 S.Ct. 1291, 55 L.Ed.2d 550 (1978). The facts underlying that characterization, however, are subject to clear error review. Id. i. Law to Apply In the Tenth Circuit, the economic substance doctrine dictates whether the Commissioner may rightfully disregard a transaction as lacking economic substance. Sala v. United States, 613 F.3d 1249 (10th Cir.2010); Keeler v. Comm’r, 243 F.3d 1212 (10th Cir.2001); Jackson v. Comm’r, 966 F.2d 598 (10th Cir.1992); James v. Comm’r, 899 F.2d 905 (10th Cir.1990); see also Casebeer v. Comm’r, 909 F.2d 1360, 1365 (9th Cir.1990) (<HOLDING>). The doctrinal framework is fairly
holding that courts must disregard transactions that are designed to comply with the literal terms of the tax code but are unlikely to produce nontax economic benefits holding that jones act claimant against the government must comply with the terms of  2675 holding that since the constitutional and statutory extradition provisions are not designed to protect fugitives but rather  are designed to facilitate the administration of justice between states the failure to comply with established procedures does not deprive the fugitive of any protected right and therefore provides no basis for a  1983 claim holding that a binding settlement on a tax liability must follow the requirements of the tax code which include the execution of a closing agreement holding that when a statutes terms are clear and unambiguous on their face there is no room for statutory construction and a court must apply the statute according to its literal meaning