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badger,

drat!

i was using an outdated version of the code (that swiss link), because the HTML formatting makes it so much easier to parse. apparently these restrictions were inserted more recently, in order to thwart manipulations by unscrupulous operators such as myself.

getting it from the horse's mouth:

http://uscode.house.gov/download/pls/26C43.txt

i see exactly the language that you quote.

darn it. that means all my tax benefits will have to have real economic substance behind them.

curses! foiled again!

[3rd-person voiceover] at a young and impressionable age, the boy whom the world would later know as "trepanne" saw his father gunned down by an alternative minimum tax; upon settling the estate, the gummint confiscated most of what few assets he had accumulated during his tragically brief life. for years afterward, trepanne's mother toiled to raise him while struggling under the burden of having an unjust revenuer refuse to qualify her substitute payments in lieu of dividends for the reduced tax rates.

as he matured and his powers grew, this seed of rancor, planted in an innocent dewy hypothalamus, soon blossomed into a florid and twisted hatred that he unleashed recklessly against an unprepared treasury.

<low camera angle, pointing upward at trepanne striking dramatic pose and shaking fist> you haven't heard the last out of me, uncle sam!

thanks badger. it is much appreciated. i just KNEW it couldn't be that easy.

trp
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