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KINGSLEY v. C. I. R.

No. 79-7662.

662 F.2d 539 (1981)

Jerrold L. KINGSLEY and June H. Kingsley, Petitioner-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided November 4, 1981.

Attorney(s) appearing for the Case

Eugene J. Brenner, Janin, Morgan & Brenner, San Francisco, Cal., for petitioners-appellants.

Gary R. Allen, Washington, D. C. (argued), for respondent-appellee; Gilbert E. Andrews, Washington, D. C., on brief.

Before GOODWIN, SKOPIL, and REINHARDT, Circuit Judges.

SKOPIL, Circuit Judge:

Taxpayers appeal from a decision of the Tax Court holding that they must pay tax on interest income imputed under I.R.C. § 483 on the deferred delivery of stock in a corporate reorganization. Gain on the shares transferred in the reorganization was not recognized under I.R.C. §§ 354, 368. Taxpayers argue on appeal that section 483 may not be applied to a section 354 reorganization, that section 483 by its own terms does not apply...

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