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  5. 99 T.C. 223 (1992)
 

CANTERBURY v. COMMISSIONER

Docket Nos. 38037-87, 31477-88, 31478-88, 31479-88, 10551-89, 13576-89, 14540-89, 14849-89, 15037-89, 15038-89, 16033-89.

99 T.C. 223 (1992)

CHARLES D. CANTERBURY AND DIANE M. CANTERBURY, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 17, 1992.

Attorney(s) appearing for the Case

N. Jerold Cohen and J.D. Fleming, Jr., for petitioners.

Jack E. Prestrud and J. Scott Broome, for respondent.

RUWE, Judge:

Petitioners are McDonald's franchisees in the San Diego, California, and Cleveland, Ohio, areas. Petitioners each acquired their franchises as part of the purchase of an existing McDonald's restaurant operation from either a McDonald's franchisee or from one of McDonald's wholly owned subsidiaries, collectively referred to as McDonald's Operating Co. (McOpCo).2 These purchases were made during the period 1972 to 1984...

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