- 9 - not determinative, their existence provides a basis for "skepticism" in accepting the form of the transaction. See Gordon v. Commissioner, 85 T.C. at 325-326. Moreover, as we also noted in Gordon, the pattern of tax benefits flowing from the transactions involved herein are such as to constitute "a yellow caution signal on our road to decision." Id. at 326. Second, a substantial portion of the stipulation dealt with assets possessed by the participants other than petitioner during the years at issue. While the values of those assets, particularly those of a corporation owned by the daughters, is not clearly established, it would appear that substantial amounts were involved and petitioner argues that the availability of such assets as a potential source of payment for the remaining interests of Nancy, Meredith, and Permenter in the bonds should be considered in determining whether such interests were independently purchased. We agree with respondent that the availability of such assets is irrelevant to the issue before us. That such assets might have been used does not answer the question of how to characterize the transactions involved herein where the funds used were supplied by petitioner.7 6(...continued) "relationship" should not be treated differently in view of the fact that we have concluded that sec. 167(e) does not impact our conclusion. See infra p. 13. 7 We note that in Gordon v. Commissioner, 85 T.C. 309, 328 (1985), we indicated that the presence of other assets available (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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