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JACOBSON v. C.I.R.

No. 91-2934.

963 F.2d 218 (1992)

Richard O. JACOBSON, Cheryl H. Jacobson, Lawrence E. Larson, and Donna C. Larson, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided May 1, 1992.

Attorney(s) appearing for the Case

Carlton T. King, Des Moines, Iowa, argued (Kelly L. McCarty, on brief), for appellants.

Frank P. Cihlar, Washington, D.C., argued (Gary R. Allen and Robert S. Pomerance, on brief), for appellee.

Before LOKEN, Circuit Judge, BRIGHT, Senior Circuit Judge, and HANSEN, Circuit Judge.

PER CURIAM.

Richard O. Jacobson, Cheryl H. Jacobson, Lawrence E. Larson, and Donna C. Larson appeal from the tax court's1 decision characterizing the formation of a partnership, the Metropolitan-Jacobson Development Venture (Venture),2 as a nontaxable capital contribution by JWC to Venture of 25 percent of JWC's interest in certain property (the McDonald properties...

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