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from the present cases. The taxpayer and Mr. Hansen jointly
purchased a parcel of land which the corporation planted,
harvested, and attended to in a manner typical of other farm
corporations in the area. In the instant cases, petitioners and
the Family Trusts jointly formed limited partnerships with
petitioners owning, albeit indirectly, virtually the same assets
that petitioners had previously owned outright; i.e., Federal
Government bonds. More specifically, petitioners liquidated
their interests in U.S. Government securities, held directly or
through Net Venture, in order to fund the distributions made to
their shareholders. Subsequently, petitioners acquired term
interests in the limited partnerships which, in turn, reinvested
petitioners' funds in entities such as Net Venture and Gopher
Fund——investment partnerships owning U.S. Government obligations.
Unlike in Kornfeld v. Commissioner, 137 F.3d 1231 (10th Cir.
1998), Gordon v. Commissioner, 85 T.C. 309 (1985), and Richard
Hansen Land, Inc. v. Commissioner, supra, where consideration
moved to a third party, in the instant cases, funds remained
within the same family group. For example, in the case of
Lincoln, the amounts contributed by Lincoln and the Lincoln
Family Trusts to the Lincoln Partnerships, if viewed as an
aggregate of all the members, can aptly be described as transfers
of money from that family's front pocket to its back pocket.
This makes the case against petitioners even stronger; here,
related parties obtained tax benefits without making any outlays
of money to third parties. A mere shuffling around of income
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