Everything You Always to Know About Farid but Were Afraid to Ask

Abstract

Younger readers might be interested to know that Everything You Always Wanted to Know About Sex but were Afraid to Ask was a 1972 Woody Allen film that took its title from a book of the same name by David Reuben, M.D. Unlike the film, the book was not comedic. Indeed, Dr. Reuben was not happy about the movie and told the L.A. Herald-Examiner, “I didn’t enjoy the movie because it impressed me as a sexual tragedy. Every episode in the picture was a chronicle of sexual failure, which was the converse of everything in the book.” Jeff Stafford, Everything You Always Wanted to Know About Sex . . . But Were Afraid to Ask, TURNER CLASSIC MOVIES, http://www.tcm.com/thismonth/article/?cid=12726&rss=mrqe (last visited July 25, 2012). This Article suggests that the Farid story is more like Allen’s movie than Reuben’s book.Students engaged in the study of federal income taxation routinely examine the case of Farid-es-Sultaneh v. Commissioner, in which the Court of Appeals for the Second Circuit addressed a wife’s tax basis in stock she received under the terms of an antenuptial agreement. While the case invariably engenders a lively and engaging class discussion, the black letter law ultimately is straightforward: her basis equaled the fair market value of the shares on the date they were received because they were acquired for consideration (that being the release of marital rights in her future husband’s property). The government had argued that her basis was the same as her husband’s (a carryover basis) because she received the stock as a gift.Perhaps students’ enthusiasm for the case results from a sense that they simply do not know the full story. After all, why would an engaged woman accept stock worth $787,500 in exchange for the possibility of receiving over $33 million upon her husband’s death — particularly when her fiancé was twenty-five years her senior with a life expectancy of only sixteen and one-half years? The recital of facts in the court’s opinion reflects that the marriage was brief and, one might suspect, tumultuous. Students are also confused by the case name: how did an American citizen end up as Farid-Es-Sultaneh? Alas, neither the trial court nor the Court of Appeals betrayed even the slightest interest in the taxpayer’s motives or the details underlying what surely must have been a titillating tale