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Petitioners argue that Richard Hansen Land, Inc. v. Commis-
sioner, T.C. Memo. 1993-248, supports their amortization of the
term interests. That case, however, is distinguishable. As
stated earlier, a few very pertinent facts set apart Richard
Hansen Land, Inc. v. Commissioner, supra, from the cases at bar.
First, the corporation's payment of wages to Mr. Hansen was a
separate and distinct transaction, one whose bona fides were
never questioned by the Commissioner. Id. The payment of wages
represented an ordinary and recurring part of the farming
corporation's business. By way of contrast, CGF and Lincoln
undertook redemptions and declared dividends as part of a plan to
provide funds for the purchase of the remainder interests.
Indeed, as Mr. Page described the plan: "The major portion of
the funds for the purchase of the remainder interest * * * is
provided from the after-tax proceeds of a[n] * * * extraordinary
dividend". Generally speaking, a dividend is defined as
extraordinary when it is unusual in amount and paid at an
irregular time because of a particular corporate event. Black's
Law Dictionary 587 (6th ed. 1990). Petitioners' distributions,
occurring within months of the limited partnerships' being
formed, were far from being recurring events in the cycle of
corporate operations; rather, they were extraordinary, nonrecur-
ring distributions that were made for a specific purpose as part
of a prearranged plan.
The nature of the underlying transaction also serves to
distinguish Richard Hansen Land, Inc. v. Commissioner, supra,
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