FEHRS FINANCE COMPANY v. C. I. R.

Nos. 72-1638, 73-1068.

487 F.2d 184 (1973)

FEHRS FINANCE COMPANY, Appellant, Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Appellee, Cross-Appellant.

United States Court of Appeals, Eighth Circuit.

Decided November 6, 1973.


Attorney(s) appearing for the Case

William P. Sutter, Chicago, Ill., for Fehrs Finance Co.

Michael L. Paup, Atty., Tax Div., Dept. of Justice, Washington, D. C., for the Commissioner.

Before HEANEY, STEPHENSON and WEBSTER, Circuit Judges.


STEPHENSON, Circuit Judge.

The focal point of this controversy concerns the basis attributable to certain stock in the hands of the acquiring corporation in connection with a redemption of stock through the use of related corporations pursuant to 26 U.S.C. §§ 304(a) and 362(a)(2).

Our task is to review the decision of the United States Tax Court1 wherein, after an extensive examination of the facts and the several sub...

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