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HILDEBRAND v. C.I.R.

No. 91-70030.

967 F.2d 350 (1992)

James HILDEBRAND, et al., Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 26, 1992.

Attorney(s) appearing for the Case

Edward G. Lavery, Hercules, Lavery, Bernstein & Kennedy, Dallas, Tex., for petitioners-appellants.

Gary R. Allen, U.S. Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before BOOCHEVER, BEEZER and TROTT, Circuit Judges.

TROTT, Circuit Judge:

James and Mary Hildebrand (the "Hildebrands"), and Leland and Irene Waltuck (the "Waltucks") (collectively, the "taxpayers") bought from Kilburn Vacation Homeshares, Inc. ("Kilburn") timeshare vacation homes in and around the Park City ski resort in Utah. The purchase contract provided for a down payment, and small annual interest payments for the first 10 years; the balance of the interest and principal...

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