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CONSOLIDATED INDUSTRIES, INC. v. C.I.R.

No. 1269, Docket 85-4025.

767 F.2d 41 (1985)

CONSOLIDATED INDUSTRIES, INC., Joseph C. Valentine and Shirley R. Valentine, Ronald J. Clayton and Jane H. Clayton, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Second Circuit.

Decided July 26, 1985.

Attorney(s) appearing for the Case

Karl Fryzel, Boston, Mass. (Chester M. Howe, Gaston Snow & Ely Bartlett, Boston, Mass., of counsel), for petitioners.

Kenneth Greene, Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Jonathan S. Cohen, William A. Whitledge, Tax Div., Dept. of Justice, Washington, D.C., of counsel), for respondent.

Before MANSFIELD, MESKILL and NEWMAN, Circuit Judges.

PER CURIAM.

Consolidated Industries, Inc., a Connecticut corporation, its shareholders, Joseph C. Valentine and Ronald J. Clayton, and their wives, appeal from decisions of the United States Tax Court dated January 16, 1985 involving deficiencies in the income tax liabilities of the individual petitioners.

The corporation is an accrual basis, calendar year taxpayer. The individual taxpayers are officers of the corporation and own all of its stock. In 1976...

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