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NUTT v. C. I. R.

Nos. 18950, 18951.

351 F.2d 452 (1965)

John F. NUTT and Eileen M. Nutt, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

Rehearing Denied November 9, 1965.

Attorney(s) appearing for the Case

William Lee McLane, Nola McLane, Thaddeus Rojek, McLane & McLane, Washington, D. C., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney, David I. Granger, and John B. Jones, Jr., Acting Asst. Atty. Gen., Dept. of Justice, Washington, D. C., for respondent.

Before CHAMBERS, POPE and JERTBERG, Circuit Judges.

CHAMBERS, Circuit Judge:

John and Eileen Nutt, husband and wife, residents of Eloy, Arizona, are farmers. They seek review here of twin decisions of the Tax Court adverse to them. In August, 1955, as the cotton harvesting season was approaching they formed two Arizona corporations. One was Rancho Tierra Prieta and the other was Black Land Farms, Inc.

To Tierra Prieta, they promptly transferred about 1,150 acres of...

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