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Commercial and Taxation Laws
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A corporation negotiates a genuine sale directly to Buyer Z. To hide part of the corporation’s gain, its controller inserts a nominal intermediary who bears no real commercial role. Prearranged documents show two same-day sales, although the parties know the corporation is the true seller to Z. The structure is deliberately used to mislead the BIR and pay less than the lawful tax. Following Estate of Toda, what is the strongest conclusion?