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JOHNSON v. C. I. R.

No. 79-1619.

652 F.2d 615 (1981)

Harry J. JOHNSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

April 13, 1981.

Attorney(s) appearing for the Case

George V. Fisher, Krumm, Schwenker & Fisher, David Skrobot, Columbus, Ohio, for petitioner-appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert Andrews, Richard Perkins, Lester Stein, Libero Marinelli, Jr., Tax Div., U. S. Dept. of Justice, Acting Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Carleton D. Powell, Washington, D. C., additional counsel for Dept. of Justice.

Before BOYCE F. MARTIN, Jr., and JONES, Circuit Judges and CELEBREZZE, Senior Circuit Judge.

ORDER

Harry J. Johnson appeals from a judgment of the Tax Court affirming the Commissioner's determination of an income tax deficiency.

Johnson Mechanical Contractors, Inc., (JMC) a wholly owned corporation of the taxpayer, disbursed funds to the taxpayer and to his sole proprietorship, H.J. Johnson Enterprises. JMC also made distributions to the taxpayer's wholly owned corporation, Central Dodge Inc. (Dodge), and to the taxpayer's son's business.

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