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PIGGY BANK STATIONS, INC. v. C.I.R.

No. 84-4042.

755 F.2d 450 (1985)

PIGGY BANK STATIONS, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 21, 1985.

Attorney(s) appearing for the Case

Towner Leeper, El Paso, Tex., for petitioner-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Carleton D. Powell, Michael L. Paup, Chief, Appellate Sec., John P. Griffin, Tax Div., Dept. of Justice, Joel Gerber, Acting Chief Counsel, John H. Menzel, Director, Tax Lit. Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before GEE, WILLIAMS and JOLLY, Circuit Judges.

GEE, Circuit Judge:

Piggy Bank Stations, Inc. (Stations) and Piggy Bank, Inc. brought an action in the United States Tax Court contesting the assertion of income tax deficiencies against them by the Commissioner of Internal Revenue (the "Commissioner"). The tax court held for the Commissioner. We affirm.

I.

Sam S. Klink and William Johnstone owned equal shares of two affiliated corporations, Piggy Bank Land, Inc. (Land) and Stations. Stations operated...

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