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GREAT FALLS NATIONAL BANK v. UNITED STATES

Civ. No. 3178.

388 F.Supp. 577 (1975)

The GREAT FALLS NATIONAL BANK, a national banking corporation, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Montana, Great Falls Division.

January 29, 1975.

Attorney(s) appearing for the Case

Richard F. Gallagher, Church, Harris, Johnson & Williams, Great Falls Mont., for plaintiffs.

James N. Flaherty, Tax Div., Dept. of Justice, Washington, D. C., for defendant.

OPINION

RUSSELL E. SMITH, Chief Judge.

This tax refund case was submitted on an agreed statement of facts.

Taxpayers, Glenn A. Woodbury and Leo A. Woodbury,1 were partners. In the years 1958, 1959, and 1960, income shown on the partnership return was allocated equally between them. In the year 1960 they traded a ranch in Nevada for a ranch in Montana, and for income tax purposes treated as nontaxable an exchange of some...

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