The taxpayer and the estate of his mother co-owned (as tenants-in-common) a dairy farm and as well as the livestock, farming equipment, feed, milk quota and other farming assets. All the estate's interest and a portion of the taxpayer's interest in the farmland was sold to a third party housing developer (who leased the lands back to the taxpayer pending development), with the taxpayer using the sales proceeds received by him to purchase all of the Estate (non-realty) farming assets.