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J. F. STEVENHAGEN CO. v. COMMISSIONER OF INTERNAL REVENUE

Nos. 76-1265, 76-1266.

551 F.2d 106 (1977)

The J. F. STEVENHAGEN CO. et al., Appellants, v. The COMMISSIONER OF INTERNAL REVENUE, Appellee. The J. F. STEVENHAGEN CO., Appellee, v. The COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Sixth Circuit.

Decided March 8, 1977.

Attorney(s) appearing for the Case

Samuel Goldman, Goldman, Greene & Tsarnas, Neil B. Greene, Akron, Ohio, for J. F. Stevenhagen Co., and others.

Scott P. Crampton, Gilbert Andrews, Asst. Attys. Gen., Tax Div., U. S. Dept. of Justice, Leonard J. Henzke, Richard Farber, Meade Whitaker, Chief Counsel, I. R. S., Washington, D. C., for C. I. R.

Before PHILLIPS, Chief Judge, EDWARDS, Circuit Judge, and SILER, District Judge.

PER CURIAM.

These are consolidated appeals from the United States Tax Court, styled as follows: The J. F. Stevenhagen Co., et al. v. Commissioner, No. 2148-72; John F. Stevenhagen and Patricia Stevenhagen v. Commissioner, No. 2149-72, and Jon-Way Developers, Inc. v. Commissioner, No. 2150-72.

The appellate contention before our court is that certain advances made by two sole and equal shareholders in Jon-Way Developers, Inc., were loans...

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