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1988, and 1989 with the Internal Revenue Service Center in Ogden,
Utah.
Petitioner is an attorney. For a number of years prior to
1986 and through December 1985, petitioner was engaged in the
general practice of law in several different partnerships with
various other attorneys.
Mr. John Moosbrugger (Mr. Moosbrugger) is an attorney who
has practiced law for approximately 30 years in Grand Forks,
North Dakota.
Petitioner and Mr. Moosbrugger practiced law together in a
law partnership (the law partnership) from 1966 to 1972. In
1972, the law partnership was converted to a corporation. The
law practice of petitioner, Mr. Moosbrugger, and sometimes others
remained in corporate form for several years, but was converted
back to a partnership. Over the years, other attorneys joined in
the practice of law with petitioner and Mr. Moosbrugger. The
attorneys included Mr. Don Leonard (Mr. Leonard), Mr. William
Murray (Mr. Murray), Mr. Richard Ohlsen (Mr. Ohlsen), Ms. Shirley
Dvorak (Ms. Dvorak), and Mr. Ralph Carter (Mr. Carter).
Due to the death of his son in 1985, petitioner decided that
he wanted to sell his interest in the law partnership. In 1985,
petitioner agreed to sell his partnership interest to other
members of the law partnership.
A purchase agreement between petitioner and the law
partnership (the purchase agreement) was executed by petitioner
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