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BRAMBLETT v. C.I.R.

No. 91-4145.

960 F.2d 526 (1992)

Richard H. and Patsy J. BRAMBLETT, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing and Rehearing Denied July 20, 1992.

Attorney(s) appearing for the Case

Brenda K. Leighton, Christopher F. Allison, Jr., Locke, Purnell, Rain, Harrell, P.C., Dallas, Tex., for petitioners-appellants.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Brian C. Griffin, Gary Allen, Chief, Mary Francis Clark and Francis M. Allegra, App. Section, Shirley D. Peterson, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before JOLLY, JONES, and EMILIO M. GARZA, Circuit Judges.

Rehearing and Rehearing En Banc Denied July 20, 1992.

E. GRADY JOLLY, Circuit Judge:

This tax appeal arises out of a series of transactions entered into by a partnership and a related corporation. The partnership, Mesquite East, and the corporation, Town East, are owned by the same four people, and each person has the same ownership interest in the corporation as he does in the partnership. Mesquite East bought several parcels of land for the stated purpose...

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