EFTA01137470Set 9
2013-02-062p854w
disregarded and the conclusions
reached in this opinion would not apply. See Harfred Operating Corporation etc."
Harfred Operating Corporation (TSB-A-86 (28)S) discusses whether a subsidiary ... reasoning should be
applicable to affiliated corporations. (This is used as authority in Harfred
Operating Corporation). I believe that this reasoning may be extended to the
situation of a grantor
https://www.justice.gov/epstein/files/DataSet%209/EFTA01137470.pdf