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VUKASOVICH, INC. v. C.I.R.

Nos. 85-7256, 85-7326.

790 F.2d 1409 (1986)

VUKASOVICH, INC., Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant. VUKASOVICH, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 2, 1986.

Attorney(s) appearing for the Case

John F. Hopkins, Hopkins, Mitchell & Carley, San Jose, Cal., for petitioner-appellee.

Teresa E. McLaughlin, Dept. of Justice, Washington, D.C., for respondent-appellant.

Before GOODWIN, HUG, and REINHARDT, Circuit Judges.

GOODWIN, Circuit Judge:

As part of a settlement of disputes arising out of a cattle-feeding agreement, Vukasovich, Inc. paid approximately $212,000 to Sunset Cattle Co., which in turn agreed to pay $200,000 to Coit Ranch, to which Vukasovich owed $237,000. The Commissioner appeals from the Tax Court's holding that Vukasovich did not realize $37,000 in income from the cancellation of indebtedness. Vukasovich cross-appeals from the Tax Court's finding that the payment...

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