TANG, Circuit Judge:
Rudolph A. and Frances N. Hardman and Hardman, Inc. appeal district court decisions upholding tax deficiencies assessed by the Internal Revenue Service. The taxpayers characterized a $109,568 payment by Hardman, Inc. as part consideration for the purchase of property from Mrs. Hardman. The Hardmans treated the payment as capital gain and Hardman, Inc. added the payment to its basis in the property. The IRS characterized the payment as a dividend...
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