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  5. 992 F.2d 226 (1993)
 

NOGUCHI v. C.I.R.

Nos. 91-70496, 91-70497.

992 F.2d 226 (1993)

Michiko NOGUCHI, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. Robert R. MIDKIFF and Evanita S. Midkiff, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 22, 1993.

Attorney(s) appearing for the Case

George G. Grubb, Carlsmith, Ball, Wichman, Murray, Case, Mukai & Ichiki, Honolulu, HI, for petitioners-appellants.

Teresa E. McLaughlin, Asst. Atty. Gen., Tax Div., Washington, DC, for respondent-appellee.

Before: BROWNING, NORRIS, and REINHARDT, Circuit Judges.

WILLIAM A. NORRIS, Circuit Judge:

Taxpayers in these consolidated appeals are residents of Hawaii. Their residences are situated on lots which they formerly leased. As lessees of houselots, they acquired rights under the Hawaii Land Reform Act of 1967 (HLRA) to acquire the fee interest in the lots at fair market value.1 They exercised those rights and acquired the fee interests by paying the lessors...

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