Robert V. SANDERS and Nancy Ritter Sanders, Appellants,
v.
Charles I. FOX, Director of Internal Revenue, Appellee.
Kimball J. CRANNEY and Janice J. Cranney, Appellants,
v.
Charles I. FOX, Director of Internal Revenue, Appellee.
N. V. SANDERS and Clover J. Sanders, Appellants,
v.
Charles I. FOX, Director of Internal Revenue, Appellees.
United States Court of Appeals Tenth Circuit.https://leagle.com/images/logo.png
March 20, 1958.
March 20, 1958.
Attorney(s) appearing for the Case
C. Preston Allen, Salt Lake City, Utah (Albert R. Bowen and Thornley K. Swan, Salt Lake City, Utah, were with him on the brief) for appellants.
James P. Turner, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Harry Baum and David O. Walter, Attys., Dept. of Justice, Washington, D. C., and A. Pratt Kesler, U. S. Atty., Salt Lake City, Utah, were with him on the brief), for appellee.
Before MURRAH, LEWIS and BREITENSTEIN, Circuit Judges.
United States Court of Appeals Tenth Circuit.
LEWIS, Circuit Judge.
Appellants, owners of all the issued stock of the Clover Club Foods Company,1 have entered into an agreement with the corporation for the redemption of their stock under a plan funded by insurance carried upon the lives of the stockholders. The insurance premiums, paid by the corporation, have been assessed against appellants as constructive dividends constituting ordinary income. The validity of this assessment is...
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