Memorandum Opinion
WHITAKER, Judge:
On June 11, 1986, this Court issued an Order to petitioners to show cause on or before June 30, 1986, "why the issues in the petition in this case that pertain to petitioners' alleged purchase of a herd of cattle from Southern Star Land & Cattle Company, Inc. should not be disposed on the basis of Jacobs v. Commissioner [Dec. 42,538(M)],
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