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DUDDEN v. C.I.R.

No. 88-2880.

893 F.2d 174 (1990)

Roger P. DUDDEN and Marcia Dudden, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided January 4, 1990.

Attorney(s) appearing for the Case

James L. Goodman, Marshalltown, Iowa, for appellants.

Howard M. Soloman, Washington, D.C., for appellee.

Before ARNOLD and MAGILL, Circuit Judges, and LARSON, Senior District Judge.

MAGILL, Circuit Judge.

Roger P. Dudden and Marcia Dudden (the Duddens), appellants and cash method taxpayers, appeal a tax court1 ruling confirming the Commissioner of Internal Revenue's (the Commissioner's) assessment of a tax deficiency for the taxable years ending December 31, 1980 and December 31, 1981. We must decide whether the acquisition of replacement gilts, pursuant to a sow lease agreement between the Duddens and their closely...

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