A GAAR reassessment upheld, primarily on the basis that the Tax Court judge was correct to look at one of the steps in the series of transactions on an objective basis and ask if the permissible objective of creditor protection could have been achieved without it, without which it was open to him to find that its primary purpose was to achieve the tax benefit.

Existence of a bona fide non-tax purpose for a series of transactions does not exclude possibility that the primary purpose of one of the transactions in the series is to obtain a tax benefit.