RINGWALT v. UNITED STATES

Nos. 76-1285 to 76-1287.

549 F.2d 89 (1977)

Jack D. RINGWALT, Appellant, v. UNITED STATES of America, Appellee. Philip L. LIESCHE and Ursula A. Liesche, Appellants, v. UNITED STATES of America, Appellee. Jack D. RINGWALT and Jean W. Ringwalt, Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided February 16, 1977.


Attorney(s) appearing for the Case

Harold W. Kauffman, William A. Day, Jr., Omaha, Neb., for appellants.

George G. Wolf, Atty., Tax Div., Dept. of Justice, Washington, D. C., for appellee; Daniel E. Wherry, U. S. Atty., Omaha, Neb., Scott P. Crampton, Asst. Atty. Gen. and Gilbert E. Andrews, Jonathan S. Cohen, Attys. Tax Div., Dept. of Justice, Washington, D. C., on brief.

Before STEPHENSON and HENLEY, Circuit Judges, and MEREDITH, District Judge.


STEPHENSON, Circuit Judge.

Jack D. Ringwalt and other taxpayers1 appeal from the district court's2 judgment disallowing their claims for income tax refunds for the year 1967. In this appeal appellants contend the district court erred in concluding that certain corporate transactions constituted a corporate reorganization rather than a liquidation producing more favorable tax treatment. For the reasons stated...

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