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HONIGMAN v. C. I. R.

Nos. 71-1927, 71-1928.

466 F.2d 69 (1972)

Jason L. HONIGMAN and Edith Honigman et al., Petitioners-Appellants, Petitioners-Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Respondent-Cross-Appellant.

United States Court of Appeals, Sixth Circuit.

August 3, 1972.

Attorney(s) appearing for the Case

Miles Jaffe, Honigman, Miller, Schwartz & Cohn, Detroit, Mich. (Michael Z. Shubow, Detroit, Mich., on the brief) for Honigman and another.

Mrs. Issie Jenkins, Atty. for Tax Division, Dept. of Justice, Washington, D.C., (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Paul M. Ginsburg, Dept. of Justice, Tax Division, K. Martin Worthy, Chief Counsel Internal Revenue Service, Washington, D.C., on the brief) for Commissioner of Internal Revenue.

Before PHILLIPS, Chief Judge, and EDWARDS and CELEBREZZE, Circuit Judges.

PHILLIPS, Chief Judge.

This is an appeal and cross-appeal from a decision of the United States Tax Court reported at 55 T.C. 1067 (1971). We affirm as to the issues on appeal and reverse as to the issue on cross-appeal.

The principal controversy involves the tax consequences of the sale of corporate property below market value to a minority shareholder. A secondary unrelated question...

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