Carol M. Read, et al. - Page 68

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          and Ms. Read gets the benefit of section 1041.  If Mr. Read did             
          not have a primary and unconditional obligation to purchase Ms.             
          Read’s stock, then we should hold that Q&A-9 does not apply, the            
          redemption of Ms. Read’s stock did not result in a constructive             
          dividend to Mr. Read, and Ms. Read’s transfer of stock to MMP               
          should be treated as a simple redemption resulting in a taxable             
          capital gain to Ms. Read.                                                   
               BEGHE, J., agrees with this dissent.                                   

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