NOONAN v. C. I. R.

Nos. 25730-25732 and 25784.

451 F.2d 992 (1971)

Lloyd F. NOONAN et al., Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. SANTA FE HOMES, INC., Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Cross-Appellant.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied December 23, 1971.


Attorney(s) appearing for the Case

Robert H. Walker (argued), Oakland, Cal., for Lloyd F. Noonan, Santa Fe Homes, Inc., and others.

William Hogan (argued), K. Martin Worthy, Chief Counsel, Internal Revenue, Johnnie Walters, Asst. Atty. Gen., Washington, D. C., for the C. I. R.

Before ELY and TRASK, Circuit Judges, and McNICHOLS, District Judge.


PER CURIAM:

The taxpayers challenge a decision of the Tax Court, reported at 52 T.C. 907 (1969). The Commissioner has taken a cross-appeal "solely to protect the Government's right to collect additional taxes from the corporation should this Court reverse the Tax Court's decisions * * *."

Four corporations were limited partners in a partnership of which Lloyd Noonan and Wilfred Winkenbach were general partners. Noonan was the...

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