- 33 -                                         
          distinguishable from the facts and question before us.  In Reese,           
          the Court of Appeals was asked to conclude (and did conclude)               
          that the taxpayer’s venture into real property construction never           
          amounted to the conduct of a trade or business.  Here, on the               
          deemed liquidation of H&C, Dover UK is deemed to have received              
          the assets of what undeniably was an ongoing business.  The                 
          question is whether that business was ever conducted by Dover UK.           
          Reese does not answer that question.13                                      
                    b.  Ouderkirk v. Commissioner and Azar Nut Co.                    
               v. Commissioner                                                        
               Ouderkirk v. Commissioner, T.C. Memo. 1977-120, involved an            
          individual who, in connection with the liquidation of a                     
          corporation, received 7,700 acres of cut-over timberland and an             
          obsolete and inefficient sawmill, both of which the taxpayer                
          contributed to a partnership owned by him and his wife.  After              
          refurbishment, the sawmill was placed in operation.  Over an 11-            
          year period, approximately 80 percent of the timber processed by            
          the sawmill was acquired from sources outside the 7,700 acres of            
          timberland owned by the partnership.  At the end of that period,            
          the partnership sold the sawmill at a loss (which it reported,              
               13  The position of the Court of Appeals for the Fifth                 
          Circuit in Reese v. Commissioner, 615 F.2d 226 (5th Cir. 1980),             
          affg. T.C. Memo. 1976-275, that a single nonrecurring venture               
          ordinarily will not be considered a trade or business, has been             
          referred to as the “one-bite” rule, a rule that has been                    
          specifically rejected by this Court.  See Cottle v. Commissioner,           
          89 T.C. 467, 488 (1987); Morley v. Commissioner, 87 T.C. 1206,              
          1211 (1986); S&H, Inc. v. Commissioner, 78 T.C. 234, 244 (1982).            
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