SILER, J., delivered the opinion of the court, in which NELSON, J., joined. WELLFORD, J. (pp. 640-641), delivered a separate opinion concurring in part and dissenting in part.
OPINION
SILER, Circuit Judge.
This case involves the tax consequences of a horse sale. The petitioners are the estate of Robert Kluener and Kluener's widow, Charlotte ("the taxpayers"). In the late 1980's, Robert Kluener ("Kluener") transferred forty-one horses to his closely...
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