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agreements here. After considering all of the factors here, we
find that the partnerships have shown that a sale occurred in
December 1983, both in form and in substance. Accordingly,
petitioners have shown that they come within the section 483
requirements, and that they are entitled to the interest
deductions.
To reflect the foregoing, and due to concessions of the
parties,
Decisions will be entered
under Rule 155.
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