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additional investment, divides nondepreciable property into two
parts, one of them being a term interest, amortization deductions
are not allowable. Lomas Santa Fe, Inc. v. Commissioner, 693
F.2d 71 (9th Cir. 1982), affg. 74 T.C. 662 (1980); United States
v. Georgia R.R. & Banking Co., 348 F.2d 278, 287-289 (5th Cir.
1965); Gordon v. Commissioner, 85 T.C. 309 (1985).
In these cases, the properties in question are partnership
interests, a type of property generally considered to be non-
amortizable. In form, petitioners acquired term interests in
limited partnerships, while the Family Trusts acquired the
remainders. We must decide whether the transactions are in
substance what they appear to be in form.
The precedents in Kornfeld v. Commissioner, 137 F.3d 1231
(10th Cir. 1998), affg. T.C. Memo. 1996-472, and Gordon v.
Commissioner, supra, require examination of all the singular
steps of a joint asset purchase to determine whether, in
substance, one party acquired full ownership of property and
carved out a remainder interest for related parties, or whether
related parties separately, and yet simultaneously, acquired term
and remainder interests in property, respectively. It is a well-
settled principle that formally separate steps in an integrated
series, focused toward a particular result, may be amalgamated
and treated as part of a single transaction.14 See Kornfeld v.
Commissioner, supra at 1235 (citing Commissioner v. Clark, 489
14This rule is often referred to as the step transaction
doctrine.
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