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v. Commissioner, T.C. Memo. 1994-201, affd. without published
opinion 86 F.3d 1162 (9th Cir. 1996), we found that the
taxpayer's transactions lacked economic substance and stated:
The various transfers among entities controlled or
owned by * * * [the taxpayer] are reminiscent of those
with which we have previously dealt. See, e.g., Karme
v. Commissioner, 73 T.C. 1163, 1171, 1173-1174 (1980)
affd. 673 F.2d 1062 (9th Cir. 1990); Bail Bonds by
Marvin Nelson, Inc. v. Commissioner, T.C. Memo. 1986-
23, affd. 820 F.2d 1543 (9th Cir. 1987); see also
Schiavenza v. United States, 52 AFTR2d 83-6364, 85-1
USTC par. 9155 (N.D. Cal. 1984). In those cases, the
taxpayers used foreign and domestic entities to make
prearranged "money movement[s]" within the "system" of
entities. Karme v. Commissioner, supra at 1169. The
funds involved in those money movements never left the
system of controlled entities. Typical of the
transactions in those cases were key documents that
"were not executed, and sometimes not even written in
final form, until long after their purported dates",
id. at 1191, loans and transfers that were made between
system entities to negate risk of loss; lenders that
were "continu[ing] to enjoy the use" of funds supplied
to other entities, id. at 1193; and back-to-back
transfers of funds made within hours of each other all
resulting in no net outlay of money by any single
entity or person. See Bail Bonds by Marvin Nelson,
Inc. v. Commissioner, supra. As in those cases, "It is
apparent that * * * [taxpayer's] transactions * * *
'did not appreciably affect [his] beneficial interest
except to reduce [his] tax'." Bail Bonds by Marvin
Nelson, Inc. v. Commissioner, supra (citing Knetsch v.
United States, 364 U.S. 361, 366 (1960), quoting
Gilbert v. Commissioner, 248 F.2d 399, 411 (2d Cir.
1957)).
Here, too, the transfers are "reminiscent" of those with
which we have previously dealt. Domestic and foreign entities
were used to make prearranged money movements within the system
of entities controlled by the Spanish investors. In December
1987, the J. Montaner-controlled companies, primarily Dapy, and
the Santandreu-controlled companies, primarily Roundabout,
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