Malcolm C. Todd and Ruth S. Todd, Appellants, v. Commissioner of Internal Revenue, Appellee, 682 F.2d 207 (9th Cir. 1982)

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US Court of Appeals for the Ninth Circuit - 682 F.2d 207 (9th Cir. 1982) Argued and Submitted July 7, 1982. Decided July 19, 1982

On Appeal from the Decision of the United States Tax Court.

Brian J. Seery, Los Angeles, Cal., for appellants.

Michael L. Paup, Ann Belanger Durney, Jay Miller, Frank P. Cihlar, Justice Dept., Tax Div., Washington, D. C., for appellee.

Before ELY, GOODWIN, and NELSON, Circuit Judges.


Essentially upon the basis of the Tax Court's OPINION, reported at 77 T.C. 246 (1981), the decision of the Tax Court is