BLUEBERRY LAND COMPANY, Inc. and Richmond Hill Land Company, Inc., Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fifth Circuit.https://leagle.com/images/logo.png
May 16, 1966.
May 16, 1966.
Attorney(s) appearing for the Case
D. H. Markstein, Jr., Birmingham, Ala., for petitioners.
Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Mitchell Rogovin, Chief Counsel, I. R. S., Aaron D. Trub, Atty., I. R. S., Johnathan S. Cohen, David O. Walter, Attys., Dept. of Justice, Washington, D. C., John B. Jones, Jr., Acting Asst. Atty. Gen., for respondent.
Before BROWN and COLEMAN, Circuit Judges, and GARZA, District Judge.
United States Court of Appeals Fifth Circuit.
JOHN R. BROWN, Circuit Judge:
The corporate Taxpayers appeal an adverse judgment after trial in the Tax Court.1 The tax problem arises out of the disposition of certain installment obligations to First Federal.2 Ostensibly the disposition was made by an intermediate corporation, which had first purchased all of Taxpayers' stock, and then liquidated Taxpayers to obtain...
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