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MUHEIM v. UNITED STATES

No. 74-1145.

524 F.2d 773 (1975)

Joseph M. and Evelyn MUHEIM et al., Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Ninth Circuit.

October 14, 1975.

Attorney(s) appearing for the Case

David W. Richter (argued), of Bilby, Thompson, Shoenhair & Warnock, Tucson, Ariz., for appellants.

George G. Wolf, Atty. (argued), U.S. Dept. of Justice, Tax. Div., Washington, D.C., for appellee.

Before CHOY and GOODWIN, Circuit Judges, and TAYLOR, District Judge.

PER CURIAM:

Following partial denial of a refund in the proceedings below, taxpayers appeal, challenging the ruling that the imputed-interest section, Internal Revenue Code of 1954, § 483,1 should be applied to payments received by taxpayers from a mining company.

In 1963, after the effective date of § 483, taxpayers entered into a contract with the Banner Mining Company whereby Banner obtained exclusive possession of...

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