Court of Appeals for the Fifth Circuit April 23, 1971, 30832, 30833 (Vincent Stackhouse and Wife, Erma Lee Stackhouse v. United States of America, Robert v. Williams and Wife, Rachel Williams v. United States)

WISDOM, Circuit Judge:

These consolidated income tax cases present the single question whether the settlement of a partnership’s liability resulting in a decrease of each partner’s share of the liabilities of the partnership should be “considered” as a distribution of money to the partners (the taxpayers). We hold that it should be so considered under § 752 of the 1954 Internal Revenue Code.