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CROWLEY v. C.I.R.

No. 91-1613.

962 F.2d 1077 (1992)

Ralph D. CROWLEY and Frances A. Crowley, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided April 28, 1992.

Attorney(s) appearing for the Case

James C. Donnelly, Jr. with whom Joan O. Vorster and Mirick, O'Connell, DeMallie & Lougee, Worcester, Mass., were on brief, for petitioners, appellants.

Janet A. Bradley with whom Gary R. Allen, Chief, Appellate Section Tax Div. and David I. Pincus, Tax Div., Washington, D.C., were on brief, for respondent, appellee.

Before SELYA, Circuit Judge, COFFIN, Senior Circuit Judge, and CYR, Circuit Judge.

CYR, Circuit Judge.

The Internal Revenue Service ("IRS") assessed a $206,935 deficiency against appellants Ralph and Frances Crowley based on their failure to declare, as taxable income in 1982, $443,769 in discretionary withdrawals by Ralph Crowley from Polar Corporation ("Polar"), a closely-held corporation of which Ralph and his three brothers were the only individual shareholders. The IRS determined that the alleged loans were taxable as "constructive dividends...

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