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LEVY v. C.I.R.

Nos. 83-7217, 83-7327.

732 F.2d 1435 (1984)

Ronald R. LEVY and Esther Levy, Petitioners-Appellants/Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee/Cross-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided May 8, 1984.

Attorney(s) appearing for the Case

Bruce I. Hochman, Barry L. Guterman, Hochman, Salkin & DeRoy, Beverly Hills, Cal., for petitioners-appellants/cross-appellees.

George Hastings, Michael Paup, Dept. of Justice, Washington, D.C., for respondent-appellee/cross-appellant.

Before CHOY, NELSON, and CANBY, Circuit Judges.

CHOY, Circuit Judge:

Ronald R. Levy and his wife Esther are two Beverly Hills residents who invested in an oil drilling venture involving Moray Oil Company, Inc. (Moray) and its wholly owned subsidiary Dubros, Inc. (Dubros), two Kansas corporations. Levy entered into three limited partnership agreements1 with Moray, covering two leases, known as the Baker and Croxton leases, in Linn County, Kansas...

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