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ESTATE OF KIRK v. C.I.R.

No. 78-1481.

634 F.2d 1048 (1980)

ESTATE of Eugene Brooks KIRK, deceased; Mary Ann Kirk, executrix, and Mary Ann Kirk, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided November 26, 1980.

Attorney(s) appearing for the Case

Jordan Stokes, III, Stokes & Anglea, Nashville, Tenn., for petitioners-appellants.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Tax Div., Dept. of Justice, Stuart E. Seigel, Chief Counsel, I. R. S., Washington, D. C., for respondent-appellee.

Before EDWARDS, Chief Judge, BOYCE F. MARTIN, Jr., Circuit Judge, and CELEBREZZE, Senior Circuit Judge.

PER CURIAM.

This is an appeal of a decision of the United States Tax Court reported at 70 T.C. 771 (1978). The issues on appeal concern the proper application of the provisions of Subchapter S (Sections 1371-1379) of the Internal Revenue Code of 1954.

Music City Songcrafters, Inc. was incorporated under the laws of Tennessee on January 23, 1962. It adopted a fiscal year ending June 30. For its fiscal years ending June 30, 1962...

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