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KLIGFELD HOLDINGS v. COMMISSIONER

Docket No. 21330-04.

128 T.C. 192 (2007)

128 T.C. No. 16

KLIGFELD HOLDINGS, KLIGFELD CORPORATION, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 30, 2007.

Attorney(s) appearing for the Case

Daniel J. Leer, for petitioner.

John A. Guarnieri, Meso T. Hammoud, and S. Katy Lin, for respondent.

OPINION

HOLMES, Judge:

Marnin Kligfeld contributed a large block of Inktomi Corp. stock to a partnership in 1999. The stock was shuttled from one partnership to another, theoretically gaining a greatly increased basis along the way. Most of this stock was sold in 1999. In 2000, the second partnership distributed the remaining stock with its allegedly increased basis along with the cash proceeds from the 1999 sale. Kligfeld sold the leftover stock...

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