The following excerpt is from Washington Athletic Club v. U.S., 614 F.2d 670 (9th Cir. 1980):
14 The cooperative housing cases fall in a separate category because of the special relationship between the shareholder-tenants and the cooperative. Since the equity of the shareholder-tenant is regarded as being increased by his payments which are used to amortize the cooperative's mortgage, such payments are held to be capital contributions. See Eckstein v. United States, 452 F.2d 1036, 1048, 196 Ct.Cl. 644 (1971).
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