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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