BLACKMUN, Circuit Judge.
At issue here is the character — as long-term capital gain or as ordinary income — of a partnership's net receipts under certain Dairy Queen contracts during the calendar years 1951-1953, inclusive.
The taxpayers are Fred C. Wernentin and his wife Esther and Robert L. Jester and his wife Bobbette. The partnership, known as Wernentin and Jester, was originally one between the two men but on January 1, 1952, was expanded...
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