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ELLIS v. COMMISSIONER

Docket No. 24592-83T.

50 T.C.M. 1202 (1985)

T.C. Memo. 1985-511

Betty Mayland Ellis v. Commissioner.

United States Tax Court.

Filed September 30, 1985.

Attorney(s) appearing for the Case

Stuart E. Seigel, Fairlea A. Sheehy, and Stanley I. Langbein, 839 17th St. N. W., Washington, D. C., for the petitioner. Robert P. Ruwe, Alfred C. Bishop, Jr., and Paul S. Horn, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined that petitioner's proposed transfer of certain agricultural properties located in Alberta, Canada (the "farmlands") to a Canadian corporation is "in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes," within the meaning of section 367,1 and that the transfer thus fails...

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