KOVTUN v. COMMISSIONER OF INTERNAL REVENUE

No. 25610.

448 F.2d 1268 (1971)

Lael KOVTUN et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

September 3, 1971.


Attorney(s) appearing for the Case

Bruce I. Hochman (argued), Harvey D. Tack, of Hochman, Salkin & DeRoy, Los Angeles, Cal., for petitioners.

Gary R. Allen (argued), IRS, Meyer Rothwacks, Thomas L. Stapleton, Jane M. Edmister, Dept. of Justice, Johnnie M. Walters, Asst. Atty. Gen., Tax Div., Washington, D. C., for respondent.

Before MERRILL and CARTER, Circuit Judges, and COPPLE, District Judge.


PER CURIAM:

The sixteen petitioning taxpayers in this case were all limited partners in S.C. Investments, Ltd., which was in turn a limited partner in Lake Murray Apartments. The other partner in Lake Murray was Sunset International Petroleum Corporation. On August 12, 1963, Lake Murray entered into a contract with Sunset under the terms of which Sunset was to construct residential buildings for a price of over $3,000,000. Sunset agreed to provide or procure financing...

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