Thomas K. McManus and Margaret F. McManus v. Commissioner of Internal Revenue, Estate of John C. Gutleben, Deceased, United California Bank, and Vera B. Gutleben v. Commissioner of Internal Revenue, Estate of Eleanor and Nelson Chick, Deceased, Nelse Chick Siler v. Commissioner of Internal Revenue

583 F.2d 443 78-2 USTC P 9748 Thomas K. McMANUS and Margaret F. McManus, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ESTATE of John C. GUTLEBEN, Deceased, United California Bank, Executor, and Vera B. Gutleben, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ESTATE of Eleanor and Nelson CHICK, Deceased, Nelse Chick Siler, Executrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Nos. 76-1527, 76-1528, 76-1531, 76-1532, 76-1760 and 76-1761. United States Court of Appeals, Ninth Circuit. Oct. 4, 1978. Paul E. Anderson (argued), San Francisco, Cal., for petitioners-appellants. Gilbert S. Rothenberg (argued), of Dept. of Justice, Washington, D. C., for respondent-appellee. Petition to Review a Decision of The Tax Court of the United States. Before CARTER, Circuit Judge, KUNZIG, Judge, * and TANG, Circuit Judge. TANG, Circuit Judge: 1 The taxpayers 1 appeal from a decision of the tax court, published at 65 T.C. 197 (1975), upholding the Commissioner's assessment of additional income taxes. We affirm. 2 Most of the facts were stipulated. The taxpayers were long-time associates in two…