- 16 - We are not persuaded otherwise by petitioners' further argument that respondent has made a number of "concessions" in the stipulations of settled issues. Petitioners claim that these concessions require respondent to concede that the interest expenses at issue are deductible. Respondent counters that the alleged "concessions" merely reflect this Court's holdings in the Seykota opinions. The record before us in these fully stipulated cases does not support petitioners' assertions. Suffice it to say that petitioners have not shown that the claimed concessions operate to confer economic substance upon the transactions at issue. On this record, those transactions are indistinguishable from those we found to lack economic substance in Seykota II. Accordingly, the interest generated by those transactions is not deductible. To reflect the foregoing, Decisions will be entered under Rule 155. (...continued) but also other deductions for items such as management fees or storage charges. However, neither here, nor in Seykota, have taxpayers proven that the existence of such other deductions make the underlying obligation one of economic substance "that can be separated from the underlying * * * scheme". United States v. Wexler, 31 F.3d 117, 125-126 (3d Cir. 1994).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
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