Frank Lyon, 435 U.S. at 576-77 (finding economic substance in a transaction where taxpayer bore risk of unpaid mortgage and construction loans). As correctly observed by the trial court, “[w]hatever exposure to risk that the [holding companies] technically experienced, the facts do not demonstrate that [they] acted as though they had any independent stake in the risks and opportunities associated with the business they were ostensibly conducting.” ¶ 30. The holding companies also did not engage in any meaningful business with third parties. While they did enter into suretyship and asset pledge agreements with the Federal Home Loan Bank of Boston, these agreements were specifically authorized and controlled by the banks for the banks’ own benefit. Cf. Moline Properties, 319 U.S. at 440 (<HOLDING>); Sherwin-Williams, 778 N.E.2d at 517 (finding
holding that a loss of consortium is separate and independent from the primary action holding that separate tax identity existed where entity engaged in its own business ventures separate from its stockholder and in independent legal actions against third parties holding that  1441c does not allow the remand of claims that are not separate and independent holding wheat threshing is a business entirely separate and independent of farming holding that lack of a separate judgment does not preclude the taking of an appeal from a district courts final decision because the parties may waive the separate judgment requirement where one has accidentally not been entered