mdpizzuto1
Level 2

Thank you for your reply. I am not concerned about discovering IRS intent, which is not relevant to me. I was merely interested in researching: (1) primary sources, (2) secondary sources,  or (3) IRS practical guidance on the topic. Having resolved the issue to my satisfaction, I thought I would share my thoughts in the Community, after which I moved on to other matters.

Have a great w/e.