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LOVELL AND HART, INC. v. C. I. R.

No. 71-1455.

456 F.2d 145 (1972)

LOVELL AND HART, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

March 2, 1972.

Attorney(s) appearing for the Case

Charles R. Hembree, Lexington, Ky., for appellant; Philip E. Wilson, on brief, Kincaid, Wilson, Schaeffer, Trimble & Hembree, Lexington, Ky., of counsel.

Richard Halberstein, Tax Dept., Dept. of Justice, Washington, D. C., for appellee; Fred B. Ugast, Acting Asst. Atty. Gen., Gilbert E. Andrews, Richard W. Perkins, Ann Belanger, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief.

Before CELEBREZZE and McCREE, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.

PER CURIAM.

We consider an appeal from a decision of the Tax Court upholding the Commissioner's determination that appellant "constructively received" certain notes issued to its shareholders in exchange for property transferred by appellant to a corporation it controlled. The facts are explicated in the opinion of the Tax Court, reported at 39 P-H Tax Ct.Mem. ¶ 70,335 (1970), and we affirm on the basis of that opinion for the reasons set forth herein.

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