Memorandum Findings of Fact and Opinion
COLVIN, Judge:
The issue for decision is whether the purported corporate purchaser of petitioners' farm assets should be recognized as a separate entity for tax purposes. As will be discussed, we hold that the corporation was not a separate taxable entity and that petitioners, "sale" of farm assets was a sham.
Respondent determined deficiencies in and additions to petitioners' federal income tax as follows...
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