I have to add my two cents here...sticking with the Valentine's Day theme.

What the court failed to recognize in Calvin is that marriage is not necessarily undertaken with a 'for profit' motive as corporate mergers and acquisitions are supposed to be.  Therefore, the court's analogy seems somewhat misguided.  After all, has a 'change in control' really occurred?  And if so, exactly how would one measure that?  No doubt, Asa and Lois Calvin had their own views.  For nothing else, the court should have allowed the application of IRC 382(l)(5) or (l)(6) and applied a long-term high-yield junk bond rate (i.e., second marriage), instead of the usual long-term tax exempt (risk free) rate.

Taxation never ceases to amaze me!