Is there a two-prong test for determining the business purpose of a transaction and the economic substance of the transaction?

This test does not demand a rigid two-step analysis. Rather, "the consideration of business purpose and economic substance are simply more precise factors to consider in the application of this court's traditional sham analysis; that is, whether the transaction had any practical economic effects other than the creation of income tax losses. (Citations omitted.) Thus, the tax court's failure to specifically delineate a two-prong test and the factual findings that support each prong is not itself fatal." Sochin v. C.I.R., 843 F.2d 351, 354 (9th Cir.1988).