GREENFIELD v. C. I. R.

No. 74-1102.

506 F.2d 972 (1975)

Clayton E. GREENFIELD and Carmen F. Greenfield, Petitioners-Appellants Cross Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee Cross Appellant. Fred S. BUGG and Pauline C. Bugg, Petitioners-Appellants Cross Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee Cross Appellant.

United States Court of Appeals, Fifth Circuit.

January 17, 1975.


Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Chief, Appellate Sec., Tax Div., Dept. of Justice, Washington, D. C., Meade Whitaker, Chief Counsel, Bobby D. Burns, Internal Revenue Service, Washington, D. C., Gary R. Allen, Atty., Robert G. Burt, Atty., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee cross appellant.

Eugene C. Heiman, Miami, Fla., for petitioners-appellants cross appellees.

Before BELL, AINSWORTH and RONEY, Circuit Judges.


BELL, Circuit Judge:

This suit arose after appellants Greenfield and Bugg were assessed $34,594.56 and $43,264 for claimed deficiencies with respect to 1964 income tax. The Commissioner grounded these assessments on two 1964 transactions which involved appellants and their wholly-owned corporations, Carline Electric Corporation ["Domestic"] and Carline, Ltd., ["Offshore"]. The Tax Court sustained the Commissioner's contention that the two transactions involved investments...

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