Constant Corporation is a family-owned corporation. In 2018, Constant redeemed stock from some of its owners. Because of the attribution rules of Code Sec. 318, the redemptions did not qualify for sale or exchange treatment. However, none of the family members like each other, and they believe that family attribution should be waived because the "bad blood" between them makes them "unrelated." Advise them about this assertion. (See Rev. Rul. 80-26; 1980-1 CB 66; D. Metzger Trust, 76 TC 42, Dec. 37,614 (1981), aff'd 82-2 USTC 99718,693 F.2d 459 (CA-6 1982); R.F. Haft Trust, 75-1 USTC 99209,510 F. 2 d 43 (CA-1 1975); and B.E. Niedermeyer, 62 TC 280, Dec. 32,621 (1974), aff'd, 76-1 UsTC 99417,535 F.2d 500 (CA-9 1976), cert. denied, 492 U.S. 1000, 97 S.Ct. 528.)