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MELINDA L. GEE TRUST v. COMMISSIONER OF INTERNAL REVENUE

Nos. 84-7405 to 84-7409, 84-7412.

761 F.2d 1410 (1985)

MELINDA L. GEE TRUST, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 28, 1985.

Attorney(s) appearing for the Case

Jay R. Oliff, San Jose, Cal., for petitioners-appellants.

Michael L. Paup, Glenn L. Archer, Richard Farber, George Hastings, Asst. Attys. Gen., Washington, D.C., for respondent-appellee.

Before HALL and WIGGINS, Circuit Judges, and SMITH, District Judge.

PER CURIAM:

Appellants are successors-in-interest and transferees of two United States corporations, International Food Technology Service, Inc. (IFTS) and L.F.G., Inc. (LFG). During 1973 and 1974, IFTS and LFG were major shareholders of Simarloo Pty., Ltd., an Australian corporation. During the fiscal year ending June 30, 1973, Simarloo realized capital gains on the sale of certain stock. Simarloo did not distribute this profit to its shareholders.

The Commissioner...

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