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ADAMS v. C. I. R.

Nos. 78-1570 to 78-1572.

594 F.2d 657 (1979)

John B. ADAMS and Linda B. Adams, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Melvin H. ADAMS and Lucille B. Adams, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Melvin H. ADAMS, Jr. and Huberta A. Adams, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided March 2, 1979.

Attorney(s) appearing for the Case

Kent O. Littlejohn, Baird, Holm, McEachen, Pedersen, Hamann & Haggart, Omaha, Neb. (argued), and Michael L. Sullivan, Omaha, Neb. on brief, for appellants.

Francis J. Gould, Atty., Tax Div., Dept. of Justice, Washington, D. C. (argued), M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, and Jonathan S. Cohen, Attys., Washington, D. C., on brief, for appellee.

Before LAY, BRIGHT and STEPHENSON, Circuit Judges.

LAY, Circuit Judge.

This is a consolidated appeal by related taxpayers to review a decision of the tax court, 69 T.C. 1040 (1978), finding taxpayers liable for a deficiency of $115,969.651 in their federal income taxes for the 1972 taxable year. The deficiency is based on the tax court's conclusion that a redemption by First Security Bank of 217 shares of its stock was a taxable dividend to the taxpayers...

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