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51 Taxes 268 (1973)
Fritz &(and) Marilyn &(and) Mike &(and) Susanne

handle is hein.journals/taxtm51 and id is 268 raw text is: Fritz & Marilyn & Mike & Susanne By EDWARD H. ROBERTSON The recent exchange of matrimonial partners may present some unique tax problems. The author, a partner in the Chicago office of Price Waterhouse & Co., has had a continuing interest in divisive reorganizations. T HE RECENT DISCLOSURE of the highly unusual trade involv- ing Fritz Peterson and Mike Kekich of the New York Yankees has generated a great deal of controversy and comment. It appears, however, that very little attention has been given to the income tax implications of the transaction. This research paper has been prepared in an attempt to fill this apparent void. In addition to the tax problems which Mike and Fritz may encounter along the way, it also appears that the concept of the exchange of spouses may open up a completely new tax planning opportunity, which, in the proper political perspective, may achieve the exhalted and dignified status of a genuine loophole. The Ways and Means Committee may want to add another subject to their already crowded agenda. Perhaps at the tax seminars next fall, a few of the distinguished tax speakers will be offering profound discourses on the subject of Tax Avoidance Possibilities in Spouse Swapping.' It is traditional in tax articles to start with a brief review of the factual background before wading into the technical discussion. So, for those readers of TAXES who have been in Madagascar or otherwise out of touch with the major news stories of the day, a recapitulation may be in order. It seems that Fritz and Marilyn Peterson and Mike and Susanne Kekich had become quite close socially and enjoyed each other's company. Somewhere along the way, each of the men became attracted to his colleague's wife, and mutatis mutandis each of the women dis- covered a not dissimilar attraction. In October, each of the athletes moved out of his own family and moved into his counterpart's resi- dence where he found not only a wife but two children. This unusual arrangement came to the attention of the baseball public in March 1973 when the group showed up in Florida at the Yankees' spring training camp. Although there is now some indication that at least one of the partici- pants has lost some of her original enthusiasm for the arrangement,2 it is 'Writers on tax subjects have often been justifiably accused of committing frightful assaults on the English language. An outstanding example is the word which was coined by an unidentified member of the group to characterize a gift between husband and wife, which gift is described as being interspousal. It appears that Messrs. Peterson and Kekich may have introduced, new shades of meaning to this uncelebrated adjective. 'In the baseball idiom, this would probably be referred to as a balk. 268 May, 1973 e TAXES-The Tax Magazine

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