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WHITE TOOL AND MACHINE CO. v. COMMISSIONER OF INTERNAL REVENUE

Nos. 81-1162, 81-1169.

677 F.2d 528 (1982)

WHITE TOOL AND MACHINE COMPANY (81-1162), Petitioner-Appellant, Roger S. White and Elaine J. White; Stephen White and Elaine D. White; Gary R. White and Kathryn M. White, (81-1169), Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee (81-1162), Respondent-Appellant (81-1169).

United States Court of Appeals, Sixth Circuit.

Decided May 5, 1982.

Attorney(s) appearing for the Case

James D. O'Connell, Highland Park, Mich., for petitioners.

N. Jerold Cohen, Chief Counsel, Emory L. Langdon, Acting Chief Counsel, Washington, D. C., John F. Murray, Michael L. Paup, Acting Asst. Attys. Gen., Tax Div., Dept. of Justice, Ann Belanger Durney, R. Russell Mather, Washington, D. C., for respondent.

Before LIVELY, KEITH and MERRITT, Circuit Judges.

ORDER

The taxpayer, White Tool and Machine Company, has appealed from a decision of the United States Tax Court, and the Commissioner of Internal Revenue has filed a cross-appeal directed to one issue decided by the Tax Court. In this case deficiencies were assessed against White Tool and Machine Company for the years 1973 and 1974 on the basis of a reallocation of income and deductions among three corporations owned and controlled by the same group of individuals...

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