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HOLMAN v. C. I. R.

Nos. 76-3671, 76-3672.

564 F.2d 283 (1977)

Francis E. HOLMAN and Eloise F. Holman, his wife, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. William M. HOLMAN and Emily L. Holman, his wife, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

November 3, 1977.

Attorney(s) appearing for the Case

William M. Holman, Seattle, Wash. (argued), for appellants.

Gilbert S. Rothenberg, Dept. of Justice, Washington, D.C. (argued), for appellee.

Before WALLACE and SNEED, Circuit Judges, and BOLDT, District Judge.

SNEED, Circuit Judge:

Francis E. Holman and William M. Holman were partners in a law firm from which, pursuant to the terms of the partnership agreement, they were expelled. As a consequence, again pursuant to the partnership agreement, they received in the taxable years of 1969 and 1970 certain amounts for their interests in the partnership "inventory" which the partnership agreement defined to mean "accounts receivable" and "unbilled services."

The Holmans...

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