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HEINZ v. C.I.R.

Nos. 84-7727 to 7732, 84-7734 to 7753, 84-7764 to 7765, 84-7796, 84-7839, 84-7852, 85-7019 to 7020, 85-7100, 85-7116, 85-7119, 85-7157 and 7158.

770 F.2d 874 (1985)

Robert K. and Carol H. HEINZ, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 9, 1985.

Attorney(s) appearing for the Case

William K. Hogan, Mill Valley, Cal., George MacVogelei, Corte Madera, Cal., for petitioners-appellants.

Bruce Ellisen, U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before NORRIS and REINHARDT, Circuit Judges, and McNICHOLS, District Judge.

PER CURIAM:

The thirty-eight taxpayers whose appeals are consolidated in this matter are limited partners of five California limited partnerships, all formed on October 28, 1976, with the stated purpose of leasing property and mining for coal. On the same day the partnerships were formed, they in turn formed a joint venture. The joint venture entered into a contract with Boone Powellton Coal Company to execute mineral subleases to certain West Virginia property leased...

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