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CAMPBELL v. UNITED STATES

No. CA 3-82-1738-C.

581 F.Supp. 1274 (1984)

William E. CAMPBELL and Gwendolyn J. Campbell v. UNITED STATES of America.

United States District Court, N.D. Texas, Dallas Division.

March 26, 1984.

Attorney(s) appearing for the Case

G. Tomas Rhodus, Lawrence R. Jones, Jr., and M. Bruce Peele, Rhodus, Jones & Brutsche, Dallas, Tex., for plaintiffs; Lester V. Baum, Johnson, Bromberg & Leeds, Dallas, Tex., of counsel.

William W. Guild, Rick K. Disney, Attys., Tax Div., Dept. of Justice, James A. Rolfe, U.S. Atty., Dallas, Tex., for defendant.

OPINION

WILLIAM M. TAYLOR, Jr., District Judge.

I. INTRODUCTION

Plaintiff, William E. Campbell, is in the real estate business. He is the sole owner of a corporation that brokers real estate. He also brokers real estate individually. Plaintiff is also the sole owner of various parcels of real estate. Lastly, he is a partner in several real estate joint ventures.

In taxable years 1976 and 1977, Mr. Campbell had losses in his individual real...

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