No. 85-2387.

826 F.2d 896 (1987)

William WHITNEY and Barbara Whitney, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 1, 1987.

Attorney(s) appearing for the Case

Edward M. Alvarez and Charles H. Sabes, San Jose, Cal., for plaintiffs-appellants.

Martha Brissette, Michael L. Paup and Robert S. Pomerance, Washington, D.C., for defendant-appellee.

Before ANDERSON, ALARCON and HALL, Circuit Judges.

J. BLAINE ANDERSON, Circuit Judge:

William and Barbara Whitney (Whitneys) are farmers in the Salinas Valley of Monterey County, California. In this regard they lease farm land from other landowners and produce crops from it. In 1975 the Whitneys sold a portion of their farming operation to Melvin and Neil Bassetti (Bassettis). A partnership was formed to purchase the farming operation. Melvin and Neil Bassetti each held a forty-nine percent interest in the partnership...

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