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APPEAL OF LAURE

Nos. 79-1231, 79-1232.

653 F.2d 253 (1981)

Appeal of George R. LAURE and Esther L. Laure. W-L MOLDING COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided June 26, 1981.

Rehearing Denied September 3, 1981.

Attorney(s) appearing for the Case

D. Alden Newland, Honolulu, Hawaii, for petitioners-appellants.

M. Carr Ferguson, Asst. Atty. Gen., Jonathan S. Cohen, Gilbert E. Andrews, Wynette Hewett, Tax Division, U. S. Dept. of Justice, Stuart E. Seigel, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before ENGEL, MERRITT and KENNEDY, Circuit Judges.

ENGEL, Circuit Judge.

Taxpayers appeal a decision of the Tax Court reported at 70 T.C. 1087 (1978). W-L Molding Company (W-L) appeals the Tax Court's decision that its merger with Lakala Aviation, Inc. (Lakala), with which it stood in a brother-sister corporation relationship was not a valid reorganization under I.R.C. § 368(a)(1)(A) because the merger lacked a business purpose and continuity...

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