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HAMILTON v. UNITED STATES

Nos. 460 79T, 461 79T and 179 80T.

687 F.2d 408 (1982)

Ferris F. and Mary Ann S. HAMILTON v. The UNITED STATES. Frederic C. and Jane M. HAMILTON v. The UNITED STATES. HAMILTON BROTHERS PETROLEUM CORPORATION v. The UNITED STATES.

United States Court of Claims.

August 25, 1982.

Attorney(s) appearing for the Case

Buford P. Berry, Dallas, Tex., attorney of record, for plaintiffs. Thompson & Knight, Dallas, Tex., of counsel.

Ellen C. Specker, Washington, D. C., with whom was Asst. Atty. Gen. Glenn L. Archer, Jr., for defendant. Theodore D. Peyser and Donald H. Olson, Washington, D. C., of counsel.

Before FRIEDMAN, Chief Judge, and DAVIS and SMITH, Judges.

ON DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT AND PLAINTIFFS' CROSS-MOTION FOR PARTIAL SUMMARY JUDGMENT

SMITH, Judge:

Plaintiffs claim income tax refunds for 1969 on grounds that the Internal Revenue Service (Service) improperly interpreted the partnership agreements of certain partnerships1 of which Ferris and Frederic Hamilton2 were the general partners. Defendant contends that certain allocation...

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