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Werner Erhard

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Erhard maintains that he had a clear business purpose for engaging in the transactions because he desired to terminate his relationship with Margolis... However, even if Erhard had a legitimate business purpose for terminating his relationship with Margolis, that did not give him a business purpose for engaging in the specific transactions at issue here. The fact that he may have had a good business reason for separating from Margolis does not necessarily justify resorting to circular money movements (that just happened to create tax benefits) to effectuate that separation.
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Diarmuid O'Scannlain, Appellate Court Judge, United States Court of Appeals, Ninth Circuit, Werner H. Erhard, Petitioner-Appellant, v. Commissioner Internal Revenue Service, Respondent-Appellee, February 8, 1995. 46 F.3d 1470, 75 A.F.T.R.2d 95-957, 95-1 USTC P 50,074

 
Werner Erhard

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