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contribution, that factor is one of many that must be considered
in determining whether the arrangement constitutes a partnership
that will be recognized for Federal tax purposes. See S.& M.
Plumbing v. Commissioner, supra at 707. In this regard, in ASA
Investerings Pship. v. Commissioner, 201 F.3d at 514, the Court
of Appeals rejected the taxpayer’s reliance on Hunt v.
Commissioner, supra, and distinguished the case in part on the
ground that “both parties [in Hunt] had a bona fide business
purpose for entering into the partnership”. Given that we
conclude (as discussed in detail below) that Brunswick and ABN
did not have a nontax business purpose for entering into the
partnerships, whether the amounts that Brunswick transferred to
ABN are properly characterized as a specified return or a
guaranteed minimum return is not dispositive. What is pertinent
is our conclusion that Brunswick paid ABN to participate in the
Saba and Otrabanda partnerships much the same as AlliedSignal
paid ABN to participate in the ASA Investerings Partnership.
B. Agreement To Share Partnership Expenses/Losses
Petitioner contends that Saba and Otrabanda can be
distinguished from the partnership under review in ASA
Investerings Pship. v. Commissioner, supra, because Brunswick and
its partners shared partnership expenses and losses. Petitioner
relies upon the parties’ stipulations that Saba and Otrabanda
paid the partnerships’ operating expenses. Petitioner further
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