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existence of a plan is given very little weight in the absence of
supporting evidence tending to show that the Commissioner’s
position is erroneous. Niedermeyer v. Commissioner, supra at
291. Instead, this Court has relied primarily on objective
evidence, such as a written plan, corporate minutes confirming
the existence of a plan, or a writing or other communication from
an involved third party, or the lack thereof, as the most
compelling evidence of the existence of a firm and fixed plan
evidencing a taxpayer’s intention regarding the redemption of its
stock. Id.; see also Monson v. Commissioner, supra; Roebling v.
Commissioner, 77 T.C. 30 (1981); Bleily & Collishaw, Inc. v.
Commissioner, supra. By focusing on the intent of the redeeming
corporation and the redeemed shareholder on the date of the
redemption, both this Court and the Court of Appeals for the
Sixth Circuit in Zenz have attempted to cull after-the-fact
attempts on the part of taxpayers to link unrelated transactions
in order to achieve favorable tax treatment, see Niedermeyer v.
Commissioner, supra, from those situations where the taxpayer
intentionally structures two or more transactions as part of a
plan to terminate the taxpayer’s ownership interest in a
corporation, see Zenz v. Quinlivan, supra.
An analysis of whether or not a firm and fixed plan existed
also entails an examination of any uncertainty in consummating
the alleged plan. Although a binding commitment to the plan is
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