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PUTOMA CORP. v. C. I. R.

No. 77-1591.

601 F.2d 734 (1979)

PUTOMA CORP., Successor by Merger of Pro-Mac Company, et al., Petitioners-Appellees Cross-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant Cross-Appellee.

United States Court of Appeals, Fifth Circuit.

August 27, 1979.

Attorney(s) appearing for the Case

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Act. Chief, Dept. of Justice, Tax. Div., Washington, D. C., Michael L. Paup, Richard Farber, Attys., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellant cross-appellee.

Richard Lee Brown, Fort Worth, Tex., for petitioners-appellees cross-appellants.

Before GODBOLD, Circuit Judge, SKELTON, Senior Judge, and RUBIN, Circuit Judge.

SKELTON, Senior Judge.

This is an income tax case that involves an appeal by the Commissioner of Internal Revenue (Commissioner or Government) from a decision of the United States Tax Court, and cross-appeals by Putoma Corporation (Putoma), successor by merger of Pro-Mac Company (Pro-Mac), with J. M. Hunt and wife, Inez Hunt, as appellees in the appeal of the Commissioner.

At all times pertinent to this case, Putoma Corporation and Pro-Mac Company were Texas...

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