If Arapua never considered itself a partner in a joint enterprise with Jetstream, it could not have contributed the receivables within the meaning of section 721(a). See, e.g., Wilkinson v. Commissioner, 49 T.C. 4, 12 (1967) ("We cannot believe that a hurriedly organized tour through sections 721 and 731 could yield such an absurd result."). The objective evidence regarding the stark divergence in the respective interests of Arapua and Jetstream with respect to the transfer of the receivables undermines petitioners' cause.
If Arapua never considered itself a partner in a joint enterprise with Jetstream, it could not have contributed the receivables within the meaning of section 721(a). See, e.g., Wilkinson v. Commissioner, 49 T.C. 4, 12 (1967) ("We cannot believe that a hurriedly organized tour through sections 721 and 731 could yield such an absurd result."). The objective evidence regarding the stark divergence in the respective interests of Arapua and Jetstream with respect to the transfer of the receivables undermines petitioners' cause.
If Arapua never considered itself a partner in a joint enterprise with Jetstream, it could not have contributed the receivables within the meaning of section 721(a). See, e.g., Wilkinson v. Commissioner, 49 T.C. 4, 12, 1967 WL 1286 (1967) (“We cannot believe that a hurriedly organized tour through sections 721 and 731 could yield such an absurd result.”). The objective evidence regarding the stark divergence in the respective interests of Arapua and Jetstream with respect to the transfer of the receivables undermines petitioners' cause.
Cf. United States v. Stafford [84-1 USTC ¶ 9316], 727 F.2d 1043, 1048 (11th Cir. 1984) (stating that the purpose of the contribution rules is "to facilitate the flow of property from individuals to partnerships that will use the property productively."). In Wilkinson v. Commissioner [Dec. 28,635], 49 T.C. 4 (1967), the taxpayers were obligees on installment notes made by their own corporation. They wished to liquidate the corporation.