Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in petitioners' 1978, 1979, and 1980 Federal income taxes in the amounts of $2,031, $2,197, and $4,593, respectively. The issues for decision are (1) whether a loss is realized when farmland is transferred in settlement of a state court lawsuit where ownership of the farmland is
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