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we gave in Blatt of a transfer of property by a spouse to a third
party that satisfies an obligation or a liability of the other
spouse, which we indicated in Blatt is one type of transfer by a
transferring spouse that constitutes a transfer of property to a
third party on behalf of a nontransferring spouse within the
meaning of Q&A-9, did not implicate the primary-and-
unconditional-obligation standard.17 If, as petitioners contend
here, we had concluded in Blatt v. Commissioner, 102 T.C. 77
(1994), a case which, like the instant cases, involved a corpo-
rate redemption in a divorce setting, that satisfaction of the
primary-and-unconditional-obligation standard as to the
nontransferring spouse is the only way in which the on-behalf-of
standard in Q&A-9 may be met in the case of such a redemption, we
16(...continued)
additional meaning of the phrase “a transfer [of property] on
behalf of” someone which we cited with approval and on which we
relied in that case, i.e., “A transfer [of property] that satis-
fies an obligation or a liability of someone”, is the only
meaning that can be attributed to the on-behalf-of standard in
Q&A-9 in the context of corporate redemptions.
17Instead, we gave the following illustration:
To illustrate the operation of Q&A 9, assume that H
owes a debt to a bank, and W, as part of a divorce
settlement, transfers her unencumbered appreciated
stock to the bank in discharge of H’s debt. This
transfer falls within the first “situation” described
in Q&A 9; that is, the transfer is required by a di-
vorce instrument and is made by W on behalf of H. * * *
[Blatt v. Commissioner, supra at 81.]
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