CGF Industries, Inc. and Subsidiaries - Page 44




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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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