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CAMPBELL v. C.I.R.

No. 90-2730.

943 F.2d 815 (1991)

William G. CAMPBELL; Norma T. Campbell, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided August 27, 1991.

Attorney(s) appearing for the Case

R. Donald Turlingon, New York City, argued (R. Donald Turlington, James A. Gouwar, Bennett I. Deutsch, Stuart B. Katz and Richard A. Ruffer, Jr., on the brief), for appellants.

Bruce R. Ellisen, Washington, D.C., argued (Gary R. Allen, Richard Farber and Bruce R. Ellisen, on the brief), for appellee.

Before BEAM, Circuit Judge, FLOYD R. GIBSON, Senior Circuit Judge, and URBOM, Senior District Judge.

BEAM, Circuit Judge.

William and Norma Campbell appeal from the tax court's decision affirming, in part, the Commissioner's assessment of deficiencies in their federal income tax for the years 1979 and 1980. The Campbells challenge the tax court's finding that partnership profits interests received by Mr. Campbell constitute income. We affirm in part and reverse in part.

I. BACKGROUND

Prior to and during the years in issue, William Campbell was employed...

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