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BRYANT v. C. I. R.

No. 24874.

399 F.2d 800 (1968)

Olin BRYANT and Vanell Bryant et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

August 12, 1968.

Attorney(s) appearing for the Case

Edward R. Smith, Smith & Baker, Lubbock, Tex., for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Dept. of Justice, Lee A. Jackson, Harry Marselli, Grant W. Wiprud, Thomas L. Stapleton, Attys., Dept. of Justice, Lester R. Uretz, Chief Counsel, I.R.S., Richard P. Milloy, Atty., I.R.S., Washington, D. C., for respondent.

Before RIVES, GEWIN and THORNBERRY, Circuit Judges.

THORNBERRY, Circuit Judge:

This appeal from a Tax Court decision, Olin Bryant and Vanell Bryant, et al., 1966, 46 T.C. 848, raises two questions, both of which were decided in favor of the Commissioner. The first is whether the sale of a farm can be accomplished by reserving to the seller a portion of the farm's future income in such a way that part of the purchase price is paid with dollars not taxed to the purchaser; the second involves...

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