William E. Campbell and Gwendolyn J. Campbell, Cross v. United States of America, Cross-Appellant

EDITH H. JONES, Circuit Judge:

Taxpayers William E. and Gwendolyn J. Campbell appeal the decision of the district court that losses from certain real estate limited partnerships were not includable in taxpayers’ net operating losses because they were not incurred in taxpayers’ “trade or business.” The government cross-appeals the district court’s contrary finding in regard to losses incurred by others of taxpayers’ limited partnerships, 581 F.Supp. 1274 (D.C.Tex.1984). We affirm in part and reverse in part.

Mr. Campbell owns interests in a number of real estate partnerships, each of which, in…