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VESTAL v. UNITED STATES

Nos. 73-1588, 73-1589.

498 F.2d 487 (1974)

Jack H. VESTAL and Mary S. Vestal, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant. John T. DANIEL and Thase F. Daniel, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eighth Circuit.

Decided May 1, 1974.

Rehearing and Rehearing Denied June 12, 1974.

Attorney(s) appearing for the Case

Louis A. Bradbury, Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellant.

Jerry T. Light, Little Rock, Ark., for plaintiffs-appellees.

Before BRIGHT and STEPHENSON, Circuit Judges, and STUART, District Judge.

Rehearing and Rehearing En Banc Denied June 12, 1974.

BRIGHT, Circuit Judge.

In 1962, cash basis-taxpayer Jack H. Vestal1 obtained contract rights to receive in the future a fractional share of a partnership in a Canadian oil and gas field development in return for services rendered to certain of the limited partners in an oil development partnership, Olds, Ltd. The oil and gas rights were subsequently sold, and Vestal received...

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