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realized a capital gain during 1993 as a result of a liquidating
distribution under section 331(a)(1).2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Petitioners resided in York, Nebraska, when they
filed their petition in this case. References to petitioner are
to Richard L. Robson.
Petitioner has worked in the insurance industry since his
graduation from college in 1963 with a degree in education. On
or about March 4, 1980, petitioner and James Klute (Klute)
decided to purchase all of the stock of Mid-Nebraska Insurors,
Inc. (Mid-Nebraska), a local insurance agency. To effect that
purchase, Mid-Nebraska borrowed $33,175 from York State Bank and
Trust Co. (York). Mid-Nebraska then lent the proceeds to
petitioner and Klute, and they used them to purchase the stock of
Mid-Nebraska. To evidence Mid-Nebraska’s loan to them,
petitioner and Klute signed a certificate of indebtedness (note)
in which they jointly and severally promised to pay Mid-Nebraska
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. For convenience, all monetary amounts are rounded to
the nearest dollar.
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