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COMPLETE FINANCE CORP. v. C.I.R.

No. 83-1907.

766 F.2d 436 (1985)

COMPLETE FINANCE CORPORATION, Sandia Auto Electric, Inc., Lomas Warehouse, Inc., New Mexico Corporations, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

July 1, 1985.

Attorney(s) appearing for the Case

Melvin D. Rueckhaus, Albuquerque, N.M., for petitioners-appellants.

Gayle P. Miller, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Jonathan S. Cohen, with her on brief), Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before McKAY, SETH and SEYMOUR, Circuit Judges.

McKAY, Circuit Judge.

The facts in this case have been stipulated, 80 T.C. 1062 (1983), and the only issues on appeal are questions of interpretation of the Internal Revenue Tax Code. The case involves three New Mexico corporations that were determined by the Commissioner to be brother and sister corporations within the definition found in 26 U.S.C. § 1563(a)(2) (1982).1 Because of this classification...

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