- 28 -
that person”. Id. We found that “petitioner [Ms. Blatt] does
not claim, and the record does not indicate, that the redemption
satisfied any obligation of [Mr.] Blatt.” Id. at 81-82. We
further concluded that Ms. Blatt did not otherwise show that she
was acting on behalf of Mr. Blatt. See id. n.12. We found that
Ms. Blatt failed to show error in respondent's determination to
treat the redemption involved there as a taxable event to her.
We held:
the record in the instant case is devoid of evidence
disproving respondent's determination that petitioner's
[Ms. Blatt's] transfer of her stock to corporation
[Phyllograph] was not on behalf of [Mr.] Blatt within
the meaning of Q&A 9. The redemption, in form, was a
transaction between petitioner and corporation; she
transferred her stock to corporation in exchange for
its appreciated value in cash. * * * [Id. at 81.]
We did not decide in Blatt v. Commissioner, supra, that only
if the primary-and-unconditional-obligation standard is satisfied
as to the nontransferring spouse may a transfer by the transfer-
ring spouse to a corporation of such transferring spouse’s stock
in that corporation be considered to be a transfer of property by
a spouse to a third party on behalf of the nontransferring spouse
within the meaning of Q&A-9.16 Moreover, the illustration that
16Nor did we indicate in Blatt v. Commissioner, supra, that
the common, ordinary meaning (i.e., the dictionary definition) of
the phrase “on behalf of” which we cited with approval and on
which we relied in that case is to be applied for purposes of
Q&A-9 only to factual contexts that were not even involved in
Blatt, i.e., to factual contexts other than corporate redemp-
tions. In addition, we did not indicate in Blatt that the
(continued...)
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