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STANDLEY v. COMMISSIONER

Docket No. 12593-90.

99 T.C. 259 (1992)

JAMES LEE STANDLEY AND CARLA RAE STANDLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 18, 1992.

Attorney(s) appearing for the Case

Thomas F. Kelly, for petitioners.

Janice D. Newell, for respondent.

GERBER, Judge:

Respondent determined a $12,983 Federal income tax deficiency for petitioners' 1986 taxable year. The issues for our consideration are: (1) Whether amounts received, through a dairy termination program, in excess of the fair market value of cows are taxable as ordinary or capital gains income; (2) the fair market value of petitioners' cows; and (3) whether petitioners are entitled to a deduction for extraordinary obsolescence or abandonment of...

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