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WILLIAMS v. C. I. R.

No. 78-1985.

627 F.2d 1032 (1980)

C. F. WILLIAMS and Jeanne V. Williams, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Tenth Circuit.

Decided July 11, 1980.

Rehearing Denied July 31, 1980.

Attorney(s) appearing for the Case

Donald E. Herrold, Tulsa, Okl. (Paul R. Hodgson, Tulsa, Okl., on briefs), for appellants.

John D. Dudeck, Jr., Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, and Richard W. Perkins, Attys., Tax Div., Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before McKAY and BREITENSTEIN, Circuit Judges and MARKEY, Chief Judge, United States Court of Customs and Patent Appeals..

BREITENSTEIN, Circuit Judge.

Taxpayers appeal from a Tax Court decision, PH Memo ¶ 78,306, which upheld the Commissioner's determination of deficiencies totaling about $285,000 for the tax years 1964 through 1969. The issue is whether cash withdrawals from closely held corporations are taxable dividends or bona fide loans. We affirm.

The petitioners-taxpayers are Clint Williams and his wife Jeanne Williams. Three Oklahoma corporations are involved, Oil...

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