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RIVER CITY RANCHES #1 LTD. v. COMMISSIONER

Dkt. Nos. 787-91, 4876-94, 9550-94, 9552-94, 9554-94, 13595-94, 13597-94, 13599-94, 14038-96.

94 T.C.M. 1 (2007)

T.C. Memo. 2007-171

River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner, River City Ranches #2 Ltd., Jeffry Bergamyer, Tax Matters Partner, River City Ranches #3 Ltd., Jeffry Bergamyer, Tax Matters Partner, River City Ranches #4 Ltd., Jeffry Bergamyer, Tax Matters Partner, River City Ranches #5 Ltd., Jeffry Bergamyer, Tax Matters Partner, River City Ranches #6 Ltd., Jeffry Bergamyer, Tax Matters Partner, et al. v. Commissioner.

United States Tax Court.

July 2, 2007.

Attorney(s) appearing for the Case

Montgomery W. Cobb, for petitioners.

Terri A. Merriam, for participating partners in docket Nos. 9554-94 and 13599-94.

Catherine J. Caballero, Thomas N. Tomashek, Gregory M. Hahn, Nhi Luu, and Dean H. Wakayama, for respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

DAWSON, Judge:

These cases are now before the Court on remand from the U.S. Court of Appeals for the Ninth Circuit. River City Ranches #1 Ltd. v. Commissioner [2005-1 USTC ¶ 50,239], 401 F.3d 1136 (9th Cir. 2005) (River City Ranches II), affg. in part, revg. in part and remanding [Dec. 55,165(M)] T.C. Memo. 2003-150 (River...

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