An examination of Dunn Trust v. Commissioner, wherein the Supreme Court refused to expand the 5-year rule of section 355 to encompass an indirect distribution. This narrow application of the 5-year rule shifts emphasis to the device clause, the more appropriate provision for evaluating sham separations.
College of Law
Northern Illinois University Law Review
"Edna Louis Dunn Trust v. Commissioner: A Movement from the 5 Year Rule to the Device Clause Under Section 355,"
Northern Illinois University Law Review: Vol. 7:
1, Article 1.
Delaine Frangos, Note, Edna Louis Dunn Trust v. Commissioner: A Movement from the 5 Year Rule to the Device Clause Under Section 355, 7 N. Ill. U. L. Rev. 113 (1987).