Edward J. PRESCOTT and Wanda D. Prescott, Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.
L. W. SIMPSON and Shirley Simpson, Appellees,
v.
UNITED STATES of America, Appellant.
United States Court of Appeals, Eighth Circuit.https://leagle.com/images/logo.png
Submitted February 17, 1977.
Decided September 14, 1977.
Attorney(s) appearing for the Case
A. H. Michals, Minneapolis, Minn., for appellants in No. 76-1634.
Jeffrey S. Blum, Atty., Tax Div., Dept. of Justice, Washington, D. C., Meade Whitaker, I. R. S., Washington, D. C., for appellee in No. 76-1634; Scott P. Crampton, Asst. Atty. Gen., and Gilbert E. Andrews and Robert A. Bernstein, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief.
Myron C. Baum, Acting Asst. Atty. Gen., and Gilbert E. Andrews, Jeffrey S. Blum and Robert A. Bernstein, Attys., Tax Div., Dept. of Justice, Washington, D. C., for appellant in No. 77-1084; and Paul A. Zoss, Jr., U. S. Atty. (former), Des Moines, Iowa, and James R. Rosenbaum, U. S. Atty. (present one), Des Moines, Iowa, on brief.
John H. Raife, Dickinson, Throckmorton, Parker, Mannheimer & Raife, Des Moines, Iowa, for appellees in No. 77-1084; Richard A. Malm, Des Moines, Iowa, on brief.
Before LAY and WEBSTER, Circuit Judges, and REGAN, Senior District Judge.
United States Court of Appeals, Eighth Circuit.
WEBSTER, Circuit Judge.
These two appeals, both of which turn on the validity of Treas.Reg. § 1.1361-16(b), have been consolidated for disposition in this Court.1 In both cases, taxpayers challenge the action of the Internal Revenue Service in treating the termination of elections by § 1361 "corporations" as resulting in taxable liquidations.
Under 26 U.S.C. § 1361,
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