Custom Chrome, Inc. and Subsidiaries - Page 22

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          treated as one if at the time the first step was entered into,              
          there was a binding commitment to undertake the later step                  
          (binding-commitment test), if the separate steps constitute                 
          prearranged parts to a single transaction intended to reach the             
          end result (end-result test), or if the steps are so                        
          interdependent that the legal relations created by one step would           
          have been fruitless without a completion of the series (mutual-             
          interdependence test).  Id. at 1429-1430.                                   
               Respondent argues that the acquisition by CC Holdings of               
          Cruze’s stock in petitioner should be treated for Federal income            
          tax purposes as a redemption and that the $650,000 constituted              
          expenses incurred in connection with that redemption.                       
          Alternatively, if the transaction is not treated as a stock                 
          redemption, respondent argues that the expenses should be                   
          capitalized due to significant long-term benefits to petitioner             
          and that no current deduction should be allowed in any year                 
          before us.                                                                  
               Petitioner argues that for Federal income tax purposes the             
          purchase of Cruze’s stock by JC Investors did not constitute a              
          stock redemption and that the expenses should be deductible                 
          either for 1992 or for 1993, the year in which JC Investors                 
          disposed of its interest in petitioner.                                     
               We agree with respondent's primary argument.                           

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