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of the facts and circumstances surrounding the agreement would
interpret the agreement and stipulations in this manner. Thus,
we hold that the agreement provides for the inclusion of Schedule
F income in the amounts shown in respondent's proposed decision
documents.
Petitioner argues that this interpretation is inconsistent
with the other terms of the agreement. An agreement should be
interpreted as a whole, and any writings which are part of the
same transaction should be interpreted together. 2 Restatement,
Contracts 2d, sec. 202 (1981). "An interpretation that gives a
reasonable meaning to all parts of the contract will be preferred
to one that leaves portions of the contract meaningless." Rink
V. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C.
319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4
Williston on Contracts, sec. 618 (3d ed. 1961).
Petitioner argues that the agreement limits the total number
and class of cattle held by the partnerships. The provision
establishing the number of cattle held by the partnerships
clearly applies, by its terms, only to depreciable cattle.
Petitioner argues that we should infer from this language that no
other cattle exist. We find this reading to be inconsistent with
other provisions of the agreement.
For example, although not directly relevant to these cases,
the agreement provides that cattle owned by the partnerships as
of January 1, 1980, will be considered fully depreciated at the
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