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cases. This leaves in controversy the sole remaining issue for
our decision: whether CGF and Lincoln are entitled to amortize
the costs of acquiring term interests in partnerships where
related persons simultaneously acquired the remainder interests
in those partnerships.
The facts of these cases are fully stipulated. The
stipulation of facts, first supplemental stipulation of facts,
stipulation of settled issues, and attached exhibits are incorpo-
rated herein by this reference. All section references are to
the Internal Revenue Code in effect for the taxable years in
issue, all Rule references are to the Tax Court Rules of Practice
and Procedure, and dollar amounts have been rounded to the near-
est dollar, unless otherwise indicated. The facts necessary for
an understanding of these cases are as follows.
Background of CGF
CGF, a Kansas corporation since 1972, maintains its princi-
pal offices in Topeka, Kansas. It is a family-owned corporation;
most of its stock is held by trusts for the benefit of members of
that family. It has been engaged, directly and through its
subsidiaries, in various businesses, including agriculture,
petroleum, real estate, manufacturing, and cable television. As
of August 1, 1988, the following entities owned the class A
common voting stock of CGF:
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