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shown above, the wages were earned by and paid to him in the
ordinary course of the corporation's business. The factual
circumstances in Richard Hansen Land, Inc. v. Commissioner,
supra, are distinguishable from the cases at bar. Here, the
amounts distributed to the Family Trusts were calculated to take
into account the after-tax proceeds that would remain available
for their use in the joint asset purchases. Robert A. Page, as
engineer of the plan, left little to chance. What we have before
us is a purely tax-motivated scheme in the form of joint asset
acquisitions for the purpose of transferring assets from peti-
tioners to the Family Trusts with minimal tax liability. As the
court in Saviano v. Commissioner, 765 F.2d 643, 654 (7th Cir.
1985), affg. 80 T.C. 955 (1983), recognized:
The freedom to arrange one's affairs to minimize taxes
does not include the right to engage in financial
fantasies with the expectation that the Internal
Revenue Service and the courts will play along. The
Commissioner and the courts are empowered, and in fact
duty-bound, to look beyond the contrived forms of
transactions to their economic substance and to apply
the tax laws accordingly. That is what we have done in
this case and that is what taxpayers should expect in
the future.
We are satisfied that, on the basis of the record as a
whole, petitioners acquired entire interests in the CGF and
Lincoln Partnerships and then transferred the remainder interests
therein to the Family Trusts. Accordingly, using Kornfeld v.
Commissioner, supra, Lomas Santa Fe, Inc. v. Commissioner, 693
F.2d 71 (9th Cir. 1982), United States v. Georgia R.R. & Banking
Co., 348 F.2d 278 (5th Cir. 1965), and Gordon v. Commissioner,
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