- 18 - Commissioner, 106 T.C. 257, 267 (1996), revd. on other grounds 121 F.3d 977 (5th Cir. 1997), we examined some of the tax consequences of a simultaneous transaction, stating: "the simultaneous nature of a number of steps does not require all but the first and the last (or "the start and finish") to be ignored for Federal income tax purposes." The regulations under section 267(f), discussed infra p. 23, would also seem to impliedly acknowledge simultaneous transactions. See sec. 1.267(f)-1T(c)(1), Temporary Income Tax Regs., 49 Fed. Reg. 46997 (Nov. 30, 1984), sec. 1.1502- 13(a)(1)(i), Income Tax Regs., discussed infra pp. 31-34. These regulations dealing with "intercompany transactions" address a situation involving the purchase and sale of an asset between corporations that are members of the same group after the sale transaction but are not necessarily members of the same group before the transaction. This seems, by logical implication, to contemplate a sale of an asset and the simultaneous association or disassociation of group members. We are dealing exactly with 13(...continued) but comprehends a situation where the rights of the parties have been previously defined and the execution of the agreement proceeds with an expedition consistent with orderly procedure. * * * [Emphasis added.] In the regulations, we have not been able to locate reference to sequential ordering for tax purposes being required when simultaneous transactions are mentioned. See also sec. 1.707- 3(f), Example (1). (Treatment of simultaneous transfers as a sale.), Income Tax Regs.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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