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Constant Corporation is a family owned corporation. In 2012, constant redeemed stock from some of its owners. Because of the attribution rules of Code Sec.

Constant Corporation is a family owned corporation. In 2012, 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.

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