JUDA v. C.I.R.

No. 88-2007.

877 F.2d 1075 (1989)

Walter JUDA and Renee Juda, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided June 12, 1989.

As Amended June 15, 1989.

Attorney(s) appearing for the Case

Geoffrey J. O'Connor, for petitioners, appellants.

Teresa E. McLaughlin, Tax Div., Dept. of Justice, with whom James I.K. Knapp, Acting Asst. Atty. Gen., Gary R. Allen and Gilbert S. Rothenberg, Tax Div., Dept. of Justice, Washington, D.C., were on brief for respondent, appellee.

Before CAMPBELL, Chief Judge, BOWNES, Circuit Judge, and CAFFREY, Senior District Judge.

BOWNES, Circuit Judge.

Appellants, Walter and Renee Juda (Juda), appeal the Tax Court's determination that they are not entitled to capital gains treatment under 26 U.S.C. § 12351 for certain transactions involving the transfer of patents.2 We affirm with one minor modification.


Our review of the facts found by the Tax Court is "only for...

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