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LEWIS v. C.I.R.

No. 93-1365.

18 F.3d 20 (1994)

Alan E. LEWIS and Harriet R. Lewis, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided March 17, 1994.

Attorney(s) appearing for the Case

David R. Andelman with whom Edward F. Fay, Colleen A. Brady and Lourie & Cutler, P.C. were on brief for appellants.

Kenneth L. Greene, Attorney, Tax Division, U.S. Department of Justice, with whom Michael L. Paup, Acting Assistant Attorney General, Gary R. Allen and Curtis C. Pett, Attorneys, Tax Division, U.S. Department of Justice, were on brief for appellee.

Before BREYER, Chief Judge, ROSENN, Senior Circuit Judge, and CYR, Circuit Judge.

BREYER, Chief Judge.

Alan and Harriet Lewis appeal from a Tax Court decision assessing taxes upon $1,062,500, which a Lewis-controlled corporation called "ILT" distributed to the Lewises in 1984. In the Tax Court's view, that money represented an ILT "dividend," paid to the Lewises at that time. See I.R.C. § 301(a), (c)(1)-(3) (1986). The Lewises disagree. They point out that a "dividend" must come from a corporation's "earnings and profits." See id...

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