LAMM v. C.I.R.

Nos. 88-2000, 88-2066.

873 F.2d 194 (1989)

Donald H. LAMM and Frances G. Lamm, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Thomas A. RYAN and Patricia J. Ryan, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Eugene A. O'BRIEN and Mary Kay O'Brien, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided April 24, 1989.


Attorney(s) appearing for the Case

Lee N. Johnson, Minneapolis, Minn., for appellants.

Stuart E. Horwich, Washington, D.C., for appellee.

Before FAGG and BEAM, Circuit Judges, and DUMBAULD, Senior District Judge.


FAGG, Circuit Judge.

The United States Tax Court ruled in favor of the Commissioner of Internal Revenue (the Commissioner) regarding the appropriate tax year in which six taxpayers were obligated to include income realized on the foreclosure sale of mortgaged property. Ryan v. Commissioner, 54 T.C.M. (CCH) 1503, 1508 (1988). The taxpayers, Donald H. and Frances G. Lamm, Thomas A. and Patricia J. Ryan, and Eugene A. and Mary...

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