Constant Corporation is a family-owned corporation. This year Constant redeemed stock from some of its owners. Because of the attribution rules of Code Sec. 318, the redemptions did not qualify for sale or exchange treatment.

However, none of the family members like each other, and they believe that family attribution should be waived because the “bad blood” between them makes them “unrelated.” Advise them about this assertion. (See Rev. Rul. 80-26; 1980-1 CB 66; D. Metzger Trust, 76 TC 42, Dec.

37,614 (1981), aff'd 82-2 ustc $9718, 693 F.2d 459 (CA-6 1982); RE Haft Trust, 75-1 ustc 99209, 510 E2d 43 (CA-1 1975); and B.E. Niedermeyer, 62 TC 280, Dec. 32,621

(1974), aff'd, 76-1 uste 99417, 535 E2d 500 (CA-9 1976), cert. denied, 492 U.S.

1000, 97 S.Ct. 528.)