McMANUS v. C. I. R.

Nos. 76-1527, 76-1528, 76-1531, 76-1532, 76-1760 and 76-1761.

583 F.2d 443 (1978)

Thomas K. McMANUS and Margaret F. McManus, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ESTATE of John C. GUTLEBEN, Deceased, United California Bank, Executor, and Vera B. Gutleben, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ESTATE of Eleanor and Nelson CHICK, Deceased, Nelse Chick Siler, Executrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

October 4, 1978.


Attorney(s) appearing for the Case

Paul E. Anderson (argued), San Francisco, Cal., for petitioners-appellants.

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

Before CARTER, Circuit Judge, KUNZIG, Judge, and TANG, Circuit Judge.


TANG, Circuit Judge:

The taxpayers1 appeal from a decision of the tax court, published at 65 T.C. 197 (1975), upholding the Commissioner's assessment of additional income taxes. We affirm.

Most of the facts were stipulated. The taxpayers were long-time associates in two construction companies. In 1954, they purchased a tract of land in Oakland, California. The tract was subdivided, and streets and...

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