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STINNETT'S PONTIAC SERVICE, INC. v. C.I.R.

No. 82-6172.

730 F.2d 634 (1984)

STINNETT'S PONTIAC SERVICE, INC., Richard W. Stinnett and Gay P. Stinnett, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

April 20, 1984.

Attorney(s) appearing for the Case

Malcolm Lewis Kneale, Miami, Fla., for petitioners.

Kenneth W. Gideon, Chief Counsel, George M. Sellinger, Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., Michael L. Paup, Chief, Appellate Section, Thomas A. Gick, U.S. Dept. of Justice, Washington, D.C., for respondent.

Before HILL and HATCHETT, Circuit Judges, and ALLGOOD, District Judge.

HATCHETT, Circuit Judge:

In this case, we review the Tax Court's holdings regarding the tax consequences of transactions involving two corporations and their common shareholder, the taxpayer. We affirm.

Facts

Richard W. Stinnett is president of Pontiac, an automobile dealership, and he owns 74% of the stock in the company.1 In the early 1960's, Pontiac established a qualified profit sharing plan for its employees. Pontiac...

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