- 16 -
See supra p. 11. See Norfolk S. Corp. v. Commissioner, 104 T.C.
13, 45-46 (1995) (revenue rulings "do not have the force of
law"), supplemented by 104 T.C. 417 (1995).
Finally, we turn to respondent's attempt to salvage her
position by arguing that the step transaction doctrine
constitutes "other law" within the meaning of section 1.1502-
80(a), Income Tax Regs., which provides:
The Internal Revenue Code, or other law, shall be
applicable to the group to the extent the regulations
do not exclude its application. * * *
We rejected respondent's attempt to invoke this provision in Walt
Disney Inc. v. Commissioner, 97 T.C. at 231-236. In our opinion
in that case, we set forth a detailed analysis of a factual
situation substantially similar to that involved herein and
concluded that there were no "meaningless or unnecessary steps"
that should be ignored as required by the step transaction
doctrine. We emphasized that respondent had blessed a
reorganization plan. See id. at 225. We see no need to repeat
that analysis herein where the facts are at least as strong as
those which were involved in Walt Disney. In this connection, it
is significant that in this case respondent has stipulated that
the requirements of section 355 were met. By so doing,
respondent has stipulated that there was a business purpose,
i.e., substance, to the transfer by petitioner to LOF Glass,
Inc., a position which is inconsistent with her position herein
that petitioner disposed of the assets by in effect transferring
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