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and then divided that ownership by retaining a life interest and
transferring the remaining interests to Nancy, Meredith, and
Permenter.
In arriving at this conclusion, we recognize that we reached
an opposite result in Richard Hansen Land, Inc. v. Commissioner,
supra. However, the factual circumstances in Hansen Land were
quite different; in particular, in the case of Richard Hansen, he
acquired the remainder interest with funds that he received as
taxable income in a transaction whose bona fides were not
questioned by respondent. His wholly owned corporation, whose
separateness was also not questioned by respondent, acquired the
amortizable term interest, and the Kammerzells utilized their own
separate funds.
Concededly, the disposition of cases such as the one before
us inevitably involves the difficult task of line drawing. But,
as we have previously observed:
the necessity of drawing lines is part of the daily
grist of judicial life and should not influence us to
adopt another rule simply to avoid difficulties in
application. See Estate of Lillie MacMunn Stewart [v.
Commissioner], 52 T.C. 830, 836 (1969), revd. on other
grounds 436 F.2d 1281 (3d Cir. 1971). [Allen v.
Commissioner, 66 T.C. 340, 346 (1976); fn. ref.
omitted.]
In view of our conclusion, we have no need to address the
application of section 167(e) in respect of the transactions
under the October 31, 1989, and June 15, 1990, agreements and the
question whether Nancy's secondary life interest constituted a
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