OPINION
SWIFT, Judge:
This matter is before us on the parties' motions and cross-motions for partial summary judgment.
In 1993, as investors in a partnership named Saddle Mountain Ranch, which owned land in Harquahala Valley, Arizona (the partnership), petitioners received a portion of $28.7 million paid by the Federal Government to certain Harquahala Valley landowners in connection with the landowners' relinquishment of the right each year...
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