CGF Industries, Inc. and Subsidiaries - Page 3




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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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