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45 percent of the gain realized on the sale of the MUI stock.
The obligation as to the remaining 55 percent falls on Linda.
Decision will be entered
under Rule 155.
4(...continued)
(1982) ("It is well established that the economic substance of a
transaction, rather than its form, controls for Federal tax
purposes."); Kraut v. Commissioner, 62 T.C. 420, 428 (1974) ("It
is a cardinal rule that, in characterizing a transaction for
purposes of taxation, we are obliged to look beyond the form in
which the parties have chosen to cast it and to draw our
conclusions from that which we perceive to be the substance of
the matter."), affd. 527 F.2d 1014 (2d Cir. 1975).
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