BUTZNER, Circuit Judge:
The United States appeals from a judgment of the district court granting John and Florence Sellers (taxpayers) a refund for taxes paid in 1965 and 1966. The issue on appeal is whether the district court properly allocated all of a limited partnership's losses to John Sellers. We reverse because we conclude that the Commissioner's allocation of 60 percent of the losses must be sustained.
I
In 1964 John Sellers agreed to form...
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