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LIKINS-FOSTER HONOLULU CORP. v. C.I.R.

No. 87-7001.

840 F.2d 642 (1988)

LIKINS-FOSTER HONOLULU CORP.; Aliamanu Homes, Ltd.; Likins-Foster Topeka Corp.; Likins-Foster Salinas Corp.; Limita Homes, Inc.; Cardiff Homes, Inc., etc., et al., Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 17, 1988.

Attorney(s) appearing for the Case

Valentine Brookes and Lawrence V. Brookes, Brookes & Brookes, San Francisco, Cal., for petitioners-appellants.

Michael L. Paup, Jonathan S. Cohen and Kenneth L. Greene, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before GOODWIN and FLETCHER, Circuit Judges, and KING, District Judge.

GOODWIN, Circuit Judge:

Taxpayers appeal from a decision of the United States Tax Court, 50 T.C.M. (CCH) 1465 (1985), upholding the Commissioner's allocation, under I.R.C. § 482 (1984), of interest income to Likins-Foster, parent corporation, as a result of interest-free loans made by it to its subsidiary. We affirm.

Likins-Foster Honolulu Corporation, a cash basis taxpayer, is the common parent of an affiliated group...

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