Trinova Corporation and Subsidiaries - Page 16

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          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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