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dation of Mr. Ramsburg’s interest in Kildare Timmy that that
partnership made to him on January 1, 1998, “was a fully taxable
transaction under �731”. That is because, according to petition-
ers, “the only property distributed in [that] liquidation was
money.” Petitioners acknowledge on brief that the linchpin in
their position under section 731, and thus in their position
under section 469(g)(1)(A), is the Court’s acceptance of their
contention that the alleged “sale of the horses from the partner-
ship to Mr. Ramsburg was a sale for tax purposes”. We thus turn
to petitioners’ contention that Mr. Ramsburg purchased Kildare
Timmy’s racing and breeding horses and stud rights for their
respective book values.
On the record before us, we find that petitioners have
failed to show that, in form or in substance, Mr. Ramsburg
purchased Kildare Timmy’s racing and breeding horses and stud
rights on January 1, 1998, immediately before that partnership
made a distribution of assets to him in liquidation of his
interest in that partnership. No money changed hands from Mr.
Ramsburg to Kildare Timmy when he allegedly purchased the horses
and the stud rights in question; nor did any money change hands
from Kildare Timmy to Mr. Ramsburg when that partnership alleg-
edly distributed the proceeds from such alleged sale to Mr.
Ramsburg in liquidation of his interest in that partnership.25
25The only money distributed by Kildare Timmy to Mr.
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