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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