BRADLEY v. UNITED STATES

No. 83-7143.

730 F.2d 718 (1984)

Merrill N. BRADLEY, et al. and John R. Murray, et al., Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

April 23, 1984.


Attorney(s) appearing for the Case

Lee C. Bradley, Jr., William Allen Smyly, Jr., Birmingham, Ala., for plaintiffs-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Douglas G. Coulter, Atty-Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before KRAVITCH, JOHNSON and HATCHETT, Circuit Judges.


HATCHETT, Circuit Judge:

In this tax case, we review the district court's ruling that the transaction between appellant taxpayers and an Alabama limited partnership constituted a sale of property, rather than an option to purchase, and that the payments derived therefrom were interest income subject to tax assessment under 26 U.S.C.A. § 61(a)(4) (West 1967). We affirm.

Facts

The appellant taxpayers were co-owners of approximately 320 acres of...

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