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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