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SPECA v. C. I. R.

Nos. 79-2191, 79-2192.

630 F.2d 554 (1980)

Gino A. SPECA and Vera Speca, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Joseph F. MADRIGRANO and Shirley M. Madrigrano, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Seventh Circuit.

Decided September 24, 1980.

Attorney(s) appearing for the Case

Stanley Gimbel, Milwaukee, Wis., for appellants.

Thomas M. Preston, Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before BAUER, Circuit Judge, CUDAHY, Circuit Judge, and NOLAND, District Judge.

NOLAND, District Judge.

This is an appeal from a finding by the Tax Court of a deficiency in income taxes by appellants Gino A. Speca and Joseph F. Madrigrano for the year 1971.1 The sole issue for review is whether the Tax Court erred in holding that certain transfers of stock by appellants to their children lacked sufficient economic reality to permit income from the stock to be taxed to the transferee-children rather than the transferor...

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