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MARK IV PICTURES, INC. v. C.I.R.

No. 91-2063.

969 F.2d 669 (1992)

MARK IV PICTURES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Russell S. DOUGHTEN, Jr. & Gertrude S. Doughten, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. HEARTLAND PRODUCTIONS, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eighth Circuit.

Decided July 13, 1992.

Attorney(s) appearing for the Case

Ronald L. Sutphin, Des Moines, Iowa, argued, for petitioner-appellant.

Kimberly S. Stanley, Dept. of Justice, Washington, D.C., argued (Gary R. Allen and Jonathan Cohen, on the brief), for respondent-appellee.

Before JOHN R. GIBSON and MAGILL, Circuit Judges, and KAUFMAN, Senior District Judge.

JOHN R. GIBSON, Circuit Judge.

Mark IV Pictures, Inc., Heartland Productions, Inc., Russell S. Doughten Jr. and Gertrude S. Doughten appeal from a decision of the tax court1 upholding the determination of the Commissioner of the Internal Revenue that they received partnership interests in exchange for performing services rather than giving property, and that the fair market value of those interests constituted income in the years 1980...

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