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P.R. FARMS, INC. v. C.I.R.

Nos. 86-7062, 86-7063, 86-7066 and 86-7069.

820 F.2d 1084 (1987)

P.R. FARMS, INC., et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 26, 1987.

Attorney(s) appearing for the Case

George W. Beatty, Washington, D.C., for petitioners-appellants.

Michael L. Paup, Jonathan S. Cohen and David M. Moore, Washington, D.C., for respondent-appellee.

Before NORRIS, BEEZER and BRUNETTI, Circuit Judges.

BEEZER, Circuit Judge:

P.R. Farms, Inc. appeals the Tax Court's determination that 1) interest earned by General Fruit Sales (a fruit broker) on proceeds from sales of P.R. Farms fruit is taxable to P.R. Farms, and 2) Palomate Storage Co. was a mere conduit through which P.R. Farms' fruit was sold. Pat and Frances Ricchiuti, husband and wife and principal shareholders in P.R. Farms appeal the Tax Court's determination that interest retained by General Fruit Sales...

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