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FANNING v. UNITED STATES

No. C-81-343-RMB.

568 F.Supp. 823 (1983)

Charles T. FANNING and Shirley J. Fanning, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Washington.

May 23, 1983.

Attorney(s) appearing for the Case

Bruce A. Charawell, Aitken, Schauble, Patrick, Neill & Charawell, Pullman, Wash., for plaintiffs.

Stanley S. Harris, U.S. Atty., Scott A. Milburn, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., for defendant.

ORDER

BILBY, District Judge.

Plaintiffs, individual taxpayers, owned and operated a farm producing wheat, barley and lentils. On March 31, 1974, all of the farm assets, except the land and a portion of the farm equipment owned by plaintiffs, were transferred into a farm corporation under 26 U.S.C. § 351 with plaintiffs as sole shareholders. In 1974, prior to incorporation, plaintiffs incurred $18,114 in...

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