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partnerships carried out the transactions for a valid business
purpose other than to obtain tax benefits; and (2) an objective
inquiry whether the CINS transactions had practical economic
effects other than the creation of tax benefits. See ACM
Partnership v. Commissioner, supra at 247-248; Horn v.
Commissioner, 968 F.2d at 1237; Casebeer v. Commissioner, 909
F.2d 1360, 1363 (9th Cir. 1990), affg. in part, revg. and
remanding in part Larsen v. Commissioner, 89 T.C. 1229 (1987),
and affg. Memorandum Opinions of this Court; Rose v.
Commissioner, 868 F.2d 851, 853-854 (6th Cir. 1989), affg. 88
T.C. 386 (1987).
A transaction imbued with economic substance normally will
be recognized for tax purposes even in the absence of a nontax
business purpose. See Northern Ind. Pub. Serv. Co. v.
Commissioner, 115 F.3d 506, 512 (7th Cir. 1997), affg. 105 T.C.
341 (1995); Larsen v. Commissioner, supra at 1253. The Court of
Appeals for the District of Columbia Circuit has held that "a
transaction undertaken for a nontax business purpose will not be
considered an economic sham even if there was no objectively
reasonable possibility that the transaction would produce
profits." Horn v. Commissioner, 968 F.2d at 1237. But cf.
Kirchman v. Commissioner, 862 F.2d 1486, 1492 (11th Cir. 1989),
(existence of a nontax business purpose does not mandate the
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