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WAGENSEN v. COMMISSIONER

Docket Nos. 5367-78, 8201-78.

74 T.C. 653 (1980)

FRED S. WAGENSEN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 9, 1980.

Attorney(s) appearing for the Case

Frank M. Cavanaugh, for the petitioner.

Richard D. D'Estrada, for the respondent.

FEATHERSTON, Judge:

In these consolidated cases, respondent determined deficiencies of $353,881, $1,806, and $1,444 in petitioner's Federal income taxes for 1974, 1975, and 1976, respectively. The issues for decision are:

(1) Whether section 10311 applies to an exchange of petitioner's ranch for another ranch and cash where he subsequently gave the ranch and some of the cash to his children.

(2) Whether a partnership...

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