OAKES, Chief Judge:
R. Timmis Ware appeals a decision of the United States Tax Court, Theodore Tannenwald, Jr., Judge, entered on April 19, 1989, determining that a portion of a payment received by Ware upon withdrawing from his law partnership was attributable to an "unrealized receivable" and therefore should have been treated as ordinary income rather than as capital gain on Ware's 1982 income tax return. We affirm.
In 1981, Ware was a partner in the New...
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