SPEARS, Chief Judge.
After having fully considered the stipulations of the parties, as well as the oral arguments and briefs of counsel submitted subsequent to the remand of this case, this Court is still of the opinion that the entire sum of $300,000 received by Tower Farm and Cattle Company, Inc. (including $35,000 over and above the $265,000 which represented the sale of land by the taxpayers to that corporation), should be considered as having been received by...
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