Kirby v. Department of Revenue

In June of 1960, plaintiffs John B. Kirby and F. W. Elder, as equal partners, purchased the Frying Pan Ranch in Malheur County, Oregon, for $150,000. The ranch consisted of 15,823 acres of land, Federal Bureau of Land Management permits covering 250,000 acres for cattle grazing, and a small amount of personal property.

On December 8, 1964, plaintiffs agreed, in writing, to sell the ranch to United Farms, a corporation, for $375,000. On January 25, 1965, plaintiffs deeded the ranch property to Norman F. Bundgard, Robert J. Bundgard, Sally Bundgard, and Joyce L. Conrow, the shareholders of…