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KNOWLTON v. C.I.R.

Nos. 85-3694, 85-3842.

791 F.2d 1506 (1986)

John F. KNOWLTON and Betty F. Knowlton, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

June 24, 1986.

Attorney(s) appearing for the Case

B. Gray Gibbs, Ronald G. Hock, St. Petersburg, Fla., Herbert L. Camp, New York City, for petitioners-appellants in 85-3694.

Fred T. Goldberg, Jr., Office of Chief Counsel, Marlene Gross, Acting Director, I.R.S., Tax Litigation, Glenn L. Archer, Jr. Asst. Atty. Gen., U.S. Dept. of Justice, Michael L. Paup, Chief Appellate Section, Roger M. Olsen, Acting Asst. Atty. Gen., Tax Div., Ann B. Durney, Washington, D.C., David M. Moore, Francis M. Allegra, William S. Estabrook, U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., for C.I.R.

Herbert L. Camp, Kristen L. Griese, New York City, for petitioners-appellants in 85-3842.

Before KRAVITCH and HATCHETT, Circuit Judges, and TUTTLE, Senior Circuit Judge.

TUTTLE, Senior Circuit Judge:

No. 85-3842.

Petitioners John F. and Betty W. Knowlton, hereinafter "taxpayers," seek to have this Court reverse the decision of the Tax Court of the United States which affirmed findings by the Commissioner of Internal Revenue of substantial deficiencies in their 1978 taxes.

I. BACKGROUND

Petitioners were shareholders of Dunmovin Corporation, a personal holding company. In 1978, Dunmovin was completely...

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