Nilo Inc. sold an asset to PPQ Partnership, which is unrelated to Nilo. PPQ immediately sold the property to Nilo Western Inc., which is a 100% controlled Nilo subsidiary. The IRS could treat the two sales as one sale of the asset by Nilo to Nilo Western by applying the:
A. Constructive payment doctrine
B. Assignment of income doctrine
C. Step transaction doctrine
D. Economic substance doctrine
Answer: C
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