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MATTER OF KING RESOURCES CO.

No. 78-1870.

614 F.2d 703 (1980)

In the Matter of KING RESOURCES COMPANY, and International Resources, Ltd., Debtors. UNITED STATES of America, INTERNAL REVENUE SERVICE, Appellants, v. KING RESOURCES COMPANY and International Resources, Ltd., Appellees.

United States Court of Appeals, Tenth Circuit.

Decided January 31, 1980.

Attorney(s) appearing for the Case

Richard W. Perkins, Atty., Tax Division, Dept. of Justice, Washington, D.C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Atty., Tax Division, Dept. of Justice, Washington, D.C. and Joseph F. Dolan, U.S. Atty., Denver, Colo., of counsel, with him on brief), for appellants.

John S. Pfeiffer, Denver, Colo. (Robert F. Wilson, Denver, Colo., with him on brief), for appellee, Charles A. Baer, Trustee, of King Resources, Co.

Before SETH, Chief Judge, HOLLOWAY and McWILLIAMS, Circuit Judges.

SETH, Chief Judge.

This appeal concerns the tax assessment and claim in bankruptcy by the Internal Revenue Service against King Resources Company for Interest Equalization Taxes under 26 U.S.C.A. (I.R.C. 1954) §§ 4911 et seq. There were other transactions and issues at trial, but the case on appeal concerns only the advance of King Resources Company (KRC) of 7.8 million dollars to pay off the indebtedness of several Bahamian trusts owed to banks apparently...

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