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GILBERTZ v. UNITED STATES

No. C82-140-K.

574 F.Supp. 177 (1983)

Lawrence E. GILBERTZ and Verna Ann Gilbertz, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Wyoming.

November 18, 1983.

Attorney(s) appearing for the Case

Claude M. Maer, Jr. and James A. Clark of Baker & Hostetler, Denver, Colo., for plaintiffs.

Ludwig H. Adams, Dept. of Justice, Washington, D.C., and Toshiro Suyematsu, Asst. U.S. Atty. for Dist. of Wyoming, Cheyenne, Wyo., for defendant.

MEMORANDUM OPINION

KERR, District Judge.

This is an action for the refund of federal individual income taxes for the year 1977. The parties have stipulated to a number of facts, relevant portions of which are presented below.

Plaintiffs are husband and wife engaged in the business of cattle raising on the Gilbertz Ranch in Campbell County, Wyoming. The ranch is comprised of two noncontiguous parts, a north portion consisting of 4,320 acres and a...

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