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MARSHALL v. C. I. R.

Nos. 73-1953 to 73-1955.

510 F.2d 259 (1975)

I. J. MARSHALL and Claribel Marshall, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Flora H. MILLER, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Tenth Circuit.

Decided January 7, 1975.

Attorney(s) appearing for the Case

James M. Parker, Schlenker, Parker, Payne & Wellborn, Albuquerque, N. M., for appellants.

George G. Wolf, Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., Scott P. Crampton, Asst. Atty. Gen., for appellee; Meyer Rothwacks, Leonard J. Henzke, Attys., Washington, D. C., of counsel.

Before HILL and SETH, Circuit Judges, and MOORE, Senior Circuit Judge.

MOORE, Senior Circuit Judge:

I. J. Marshall1 and Flora H. Miller2 are residents of Roswell, New Mexico. Both are major shareholders of the Realty Investment Company of Roswell, Inc. (Realty), a New Mexico corporation authorized, under its articles of incorporation, to conduct and engage in: a small loan business; an insurance agency; and a real estate brokerage business...

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