- 27 -
indicated that we disagreed with Arnes v. United States, supra.15
See id. at 82-83.
In Blatt v. Commissioner, supra at 81, we addressed the
meaning of the phrase “on behalf of” in Q&A-9. We stated that
“The term ‘on behalf of’ means ‘in the interest of’ or ‘as a
representative of’, Webster's Ninth New Collegiate Dictionary
(1990)”. Id. We found that Ms. Blatt did not claim, see id.
n.12, and that “the record does not indicate that petitioner [Ms.
Blatt] was acting in the interest of [Mr.] Blatt or as a repre-
sentative of [Mr.] Blatt at the time of the redemption.” Id. We
also indicated in Blatt that “A transfer that satisfies an
obligation or a liability of someone is a transfer on behalf of
14(...continued)
tion, but rather whether the transaction had satisfied
some legal obligation or liability owed by her former
husband. * * *
The Court of Appeals held in Ingham v. United States, supra,
that, because the taxpayer's sale in question to a third party
did not satisfy any such obligation or liability of the tax-
payer's former spouse, the taxpayer was not entitled to
nonrecognition treatment with respect to that sale under sec.
1041. See id. at 1245.
15We stated in Blatt v. Commissioner, 102 T.C. 77, 83
(1994):
we disagree with Arnes; any putative benefit to Blatt,
such as relief from a possible claim under marital
property distribution laws, does not mean that the
transfer by petitioner of her shares to [Phyllograph]
corporation was on behalf of Blatt. We note, however,
that the facts in Arnes are easily distinguishable from
the facts at hand. * * *
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