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meaning of the phrase “on behalf of” in Q&A-9, W's
transfer of her X stock to X was a transfer of property
by W to a third party on behalf of H within the meaning
of that temporary regulation. Held, further, pursuant
to sec. 1041(a), I.R.C., no gain shall be recognized by
W as a result of that transfer.
Mark A. Brown, for petitioner in docket No. 19001-97.
Karen E. Lewis and D. Michael O'Leary, for petitioners in
docket Nos. 19322-97 and 19328-97.
Robert W. Dillard, for respondent.
OPINION
CHIECHI, Judge: These cases are before us on cross-motions
for partial summary judgment filed by Carol M. Read (Ms. Read)
and by William A. Read (Mr. Read) and Mulberry Motor Parts, Inc.
(MMP).2 (We shall refer to the motion for partial summary judg-
ment filed by Ms. Read as Ms. Read's motion, to the motion for
partial summary judgment filed by Mr. Read and MMP as Mr. Read's
and MMP's motion, and collectively to those two motions as the
cross-motions for partial summary judgment.)
A partial summary adjudication may be made that does not
2Ms. Read incorrectly characterized her motion as a motion
for summary judgment. However, in addition to the determination
in the notice of deficiency (notice) issued to Ms. Read that we
address in this Opinion, respondent made two other determinations
in that notice, one of which respondent conceded and the other of
which is computational. Consequently, we have recharacterized
Ms. Read's motion as a motion for partial summary judgment.
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