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COATES TRUST v. C. I. R.

Nos. 71-1968 to 71-1973.

480 F.2d 468 (1973)

Rose Ann COATES TRUST et al., Appellants-Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Appellee-Respondent.

United States Court of Appeals, Ninth Circuit.

June 5, 1973.

Attorney(s) appearing for the Case

Gerald R. Hergert (argued), Joseph H. Trethewey, Trethewey & Brink, Seattle, Wash., for appellants-petitioners.

Charles E. Anderson (argued), Scott P. Crampton, Asst. Atty. Gen., Tax Div., Dept. of Justice, K. Martin Worthy, Chief Counsel, IRS, Meyer Rothwacks, Ernest J. Brown, Tax Div., Dept. of Justice, Washington, D. C., for appellee-respondent.

Before CHAMBERS, WRIGHT and KILKENNY, Circuit Judges.

EUGENE A. WRIGHT, Circuit Judge:

Sydney and Rose Ann Coates, together with their children, children's spouses, and grandchildren, owned all of the shares of two corporations, CAM Industries, Inc. (hereinafter called CAM) and Washington Industrial Products, Inc. (hereinafter called WIP). After the death of Sydney Coates, the family group agreed to combine the two corporations by having CAM "purchase" the shares of WIP.

When the transaction was complete, CAM...

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