Argued and Submitted April 11, 2001 — San Francisco, California.
WILLIAM A. FLETCHER, Circuit Judge:
William and Nicole Gladden ("the Gladdens") appeal the Tax Court's ruling that they cannot allocate any of their cost basis in farmland to the sale of water rights appurtenant to the land. The Tax Court held that the Gladdens acquired the water rights in a "separate transaction" that occurred after the original land purchase, and that the cost basis...
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