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CALLAN v. C. I. R.

No. 26774.

476 F.2d 509 (1973)

Michael C. CALLAN and Thomas J. Callan, Jr., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

March 28, 1973.

Attorney(s) appearing for the Case

Minot W. Tripp, Jr. (argued), Robert M. Winokur, Taylor, Winokur & Schoenberg, San Francisco, Cal., for petitioners-appellants.

John A. Townsend, IRS (argued), Johnnie M. Walters, Asst. Atty. Gen., Dept. of Justice, K. Martin Worthy, Chief Counsel, IRS, Meyer Rothwacks, Thomas L. Stapleton, Tax Division, Dept. of Justice, Washington, D. C., for respondent-appellee.

Before MERRILL and ELY, Circuit Judges, and SOLOMON, District Judge.

PER CURIAM:

The issue here presented for review is whether certain transactions entered into by a dissolved corporation which, after dissolution, had been determined to be a personal holding company during a period of its existence, qualified for the deficiency dividends deduction under § 547 of the Internal Revenue Code.

Appellants each owned fifty percent of the stock of Callan Investment Company, a California corporation. On March 12, 1965, the corporation...

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