Trinova Corporation and Subsidiaries - Page 26

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          States, 868 F.2d 859, 862-863 (6th Cir. 1989), the Court of                 
          Appeals for the Sixth Circuit stated as follows --                          

               the essence of the step transaction doctrine is that an                
               “integrated transaction must not be broken into                        
               independent steps or, conversely, that the separate                    
               steps must be taken together in attaching tax                          
               consequences”. * * *                                                   
                                    * * * * * * *                                     
               Under the end result test of the step transaction                      
               doctrine, “purportedly separate transactions will be                   
               amalgamated into a single transaction when it appears                  
               that they were really component parts of a single                      
               transaction intended from the outset to be taken for                   
               the purpose of reaching the ultimate result.”  King                    
               Enters., Inc. v. United States, 418 F.2d at 516. * * *                 


               Here the parties have stipulated the following facts with              
          regard to the transfer of LOF’s glass division and the change in            
          ownership of LOF Glass.                                                     
               Late in 1985, representatives of Pilkington approached LOF             
          concerning acquisition of LOF’s glass division.  During November            
          of 1985 through early March of 1986, negotiations regarding the             
          possible acquisition took place.                                            
               On March 6, 1986, LOF transferred the glass division to LOF            
          Glass, the new subsidiary that had been formed for that purpose.            
          One day later, on March 7, 1986, LOF entered into a 45-page                 
          agreement to transfer to Pilkington Holdings all of its stock               
          interest in LOF Glass in exchange for Pilkington Holdings’ stock            
          interest in LOF.                                                            





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