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RUSSELL v. C.I.R.

Nos. 86-1679, 86-1680.

832 F.2d 349 (1987)

Walter J. & Mary Ann RUSSELL (86-1679), Cannonsburg Skiing Corporation (formerly Brown-Schaefer Corporation), Transferee of the assets of Cannonsburg Skiing Corporation, Transferor (86-1680), Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided October 27, 1987.

Attorney(s) appearing for the Case

Walter J. Russell, Grand Rapids, Mich., pro se.

Jean Owens, Acting Counsel, I.R.S., Michael L. Paup, Lead Counsel, Roger M. Olsen, Tax Div., Dept. of Justice, Washington, D.C., Jonathan S. Cohen, Raymond W. Hepper, James B. Mann (argued), for C.I.R.

Before MARTIN and BOGGS, Circuit Judges, and WISEMAN, District Judge.

BOYCE F. MARTIN, Jr., Circuit Judge.

Walter J. Russell and Cannonsburg Skiing Corporation appeal the Tax Court's (T.C. Memo. 1985-15) denial of their claim against the Commissioner. Taxpayers claim that they were wrongfully denied tax benefits when the Commissioner determined that a series of transactions by them constituted a complete liquidation under Section 332 of the Internal Revenue...

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