WILLIAMS v. UNITED STATES

No. 81-1095.

680 F.2d 382 (1982)

E. G. WILLIAMS and Barbara Williams, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. J. M. PATTERSON and Louise Patterson, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. Melba Davis GREENLEE, Trustee, Trust under will of Geraldine T. Davis, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

July 14, 1982.


Attorney(s) appearing for the Case

Ben A. Douglas, Fort Worth, Tex., for plaintiffs-appellants.

John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Gary R. Allen, David English Carmack, Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before BROWN, GOLDBERG and GEE, Circuit Judges.


GOLDBERG, Circuit Judge:

Taxpayers attempted to deduct from personal income partnership losses that were incurred prior to the time the taxpayers acquired their partnership interests. The district court held that taxpayers could deduct only those losses which accrued after the date of their entry into the partnerships. We affirm: taxpayers would like to play a game of musical chairs with partnership interests and losses, but the movements of the game do not conform...

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