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really component parts of a single transaction intended from the
outset to transfer to the Ackerman group the built-in tax losses
in the SMHC receivables and stock. Invoking the
“interdependence” test, respondent argues that Generale Bank’s
and CLIS’s contributions of the SMHC receivables and stock and
Somerville S Trust’s purchase of Generale Bank’s and CLIS’s
preferred interests were so interdependent that either
transaction alone would have been fruitless without the other.
Respondent argues that these transactions should be recast as a
direct sale of the high-basis, low-value receivables to
Somerville S Trust.
Petitioner argues that the “end result” test is
inapplicable. Petitioner argues that Generale Bank’s and CLIS’s
contributions of SMHC receivables and stock and Somerville S
Trust’s purchase of Generale Bank’s and CLIS’s preferred
interests were not merely a series of steps in a single
transaction designed to transfer tax attributes but were instead
designed for SMP to acquire a film library. Petitioner also
argues that the “interdependence” test is inapplicable.
Petitioner argues that Generale Bank’s and CLIS’s contributions
of SMHC receivables and stock and Somerville S Trust’s purchase
of Generale Bank’s and CLIS’s preferred interests were not so
interdependent that either transaction alone would have been
fruitless without the other. Petitioner contends that there was
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