Andantech L.L.C., Wells Fargo Equipment Finance, Inc. (f.k.a. Norwest Equipment Finance, Inc.), Tax Matters Partner, and Wells Fargo & Co., A Partner Other Than the Tax Matters Partner, et al. - Page 93




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          The intended result from the outset was to pass the benefits and              
          burdens of the sale-leaseback transaction to RD Leasing in order to           
          allow Norwest to claim large depreciation deductions and for Mr.              
          Parmentier to make his profit through the value of RD Leasing’s               
          preferred stock.                                                              
               Thus, by applying the end result test, we will give tax                  
          consideration only to that intended result.                                   
                         c.    Interdependence Test                                     
               We reach the same conclusion by reviewing the transactions               
          under the interdependence test.  The “interdependence” test focuses           
          on whether “the steps are so interdependent that the legal                    
          relations created by one transaction would have been fruitless                
          without a completion of the series.”  Redding v. Commissioner, 630            
          F.2d 1169, 1177 (7th Cir. 1980), revg. and remanding 71 T.C. 597              
          (1979); see also Kass v. Commissioner, 60 T.C. 218 (1973), affd.              
          without published opinion 491 F.2d 749 (3d Cir. 1974); Farr v.                
          Commissioner, 24 T.C. 350 (1955); Am. Wire Fabrics Corp. v.                   
          Commissioner, 16 T.C. 607 (1951); Am. Bantam Car Co. v.                       
          Commissioner, 11 T.C. 397 (1948), affd. 177 F.2d 513 (3d Cir.                 
          1949).  This test concentrates on the relationship between the                
          steps, rather than on their “end result”.  See Sec. Indus. Ins. Co.           
          v. United States, 702 F.2d 1234, 1245 (5th Cir. 1983).                        
               The interdependence test requires a court to find whether the            
          individual steps had independent significance or had meaning only             
          as part of the larger transaction.  Penrod v. Commissioner, 88 T.C.           





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