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business purposes”); 11 Mertens, Law of Federal Income Taxation,
secs. 43.254-43.255 (1990 rev.). Under the facts of this case,
the step transaction doctrine does not require the Court to
disregard the gain realized by petitioner upon receipt of the
pesos.
Petitioner and the amici curiae make a number of additional
arguments. We find them to be without merit. Also, the amici
curiae seek to raise a number of new issues not raised in the
petition in this case. We decline to address issues not raised
in the pleadings and not properly before us.
For the reasons stated, we decline to alter the result
reached in our opinion reported at 103 T.C. 59.
Decision will be entered
under Rule 155.
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