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BRENNAN v. O'DONNELL

No. 27705.

426 F.2d 218 (1970)

Frances U. BRENNAN, as Executrix of the Last Will and Testament of William J. Brennan, Deceased, etc., et al., Plaintiffs-Appellees, v. A. J. O'DONNELL, District Director of Internal Revenue, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

May 12, 1970.

Attorney(s) appearing for the Case

Macon L. Weaver, U. S. Atty., Birmingham, Ala., Lester R. Uretz, Chief, Internal Revenue Dept., Washington, D. C., Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Chief, Appellate Section, Tax Div., Jonathan S. Cohen, Michael B. Arkin, Harry Baum, Howard M. Koff, Stuart A. Smith, Attys., Dept. of Justice, Washington, D. C., for defendant-appellant.

C. V. Stelzenmuller, Birmingham, Ala., for plaintiffs-appellees.

Before BELL, AINSWORTH and CARSWELL, Circuit Judges.

AINSWORTH, Circuit Judge.

The issue presented in this case is whether certain cash advances made by taxpayers to a corporation in which they were shareholders should be considered as creating a class of stock in the corporation for the purpose of determining the corporation's eligibility to obtain the special tax treatment made available by Subchapter S, Int.Rev.Code of 1954, §§ 1371-1377, to "small business corporations" and their shareholders. If these...

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