FOSTER v. C.I.R.

No. 83-7745.

756 F.2d 1430 (1985)

Richard H. FOSTER and Sara B. Foster, T. Jack Foster, Jr. and Patricia Foster, Jack R. Foster and Caroline Foster, and Estate of T. Jack Foster, Deceased, Gladys H. Foster, Executrix, and Gladys H. Foster, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 3, 1985.


Attorney(s) appearing for the Case

Valentine Brookes, Brookes & Brookes, San Francisco, Cal., for petitioners-appellants.

R. Pomerance, Washington, D.C., for respondent-appellee.

Before DUNIWAY, KENNEDY, and ANDERSON, Circuit Judges.


J. BLAINE ANDERSON, Circuit Judge:

In 1955, Jack Foster and his three sons formed a partnership, T. Jack Foster and Sons (Partnership), for the general purpose of dealing in property, with Jack as the managing partner. In 1958, the Partnership began to investigate the reclamation potential of Brewer's Island, a 2,600 acre undeveloped and partially submerged tract of land located about 12 miles south of San Francisco. After commissioning engineering studies, the Partnership...

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