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satisfaction of the primary-and-unconditional-obligation stan-
dard, the Treasury Department would have expressly so indicated
in Q&A-9. It did not.
We have rejected petitioners’ argument in these cases that
only if the primary-and-unconditional-obligation standard is met
as to Mr. Read may the on-behalf-of standard in Q&A-9 be satis-
fied. We shall now determine whether Ms. Read’s transfer of her
MMP stock to MMP was a transfer of property by the transferring
spouse (Ms. Read) to a third party (MMP) on behalf of the
nontransferring spouse (Mr. Read) within the meaning of Q&A-9.
We shall make that determination by applying the meanings of the
phrase “on behalf of” in Q&A-9 which we cited with approval and
on which we relied in Blatt v. Commissioner, 102 T.C. at 82.
We shall turn first to whether Ms. Read’s transfer of her
MMP stock to MMP satisfied a liability or an obligation of Mr.
Read, one of the ways in which we indicated in Blatt v. Commis-
sioner, supra, a transfer of property would be considered a
transfer of property by the transferring spouse to a third party
on behalf of the nontransferring spouse within the meaning of
Q&A-9. We find that it did not. Under the divorce judgment, Mr.
Read’s obligation24 to purchase Ms. Read’s MMP stock for the
24In support of their position that Ms. Read’s transfer of
her MMP stock to MMP does not satisfy the on-behalf-of standard
in Q&A-9, Mr. Read and MMP contend, inter alia, that “Mr. Read
would not be obligated [under the divorce judgment] to purchase
(continued...)
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