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OZIER v. COMMISSIONER OF INTERNAL REVENUE

No. 77-1466.

600 F.2d 594 (1979)

John R. OZIER and Mildred C. Ozier, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

June 29, 1979.

Attorney(s) appearing for the Case

H. Stennis Little, Jr., Larry T. Thrailkill, John B. Owens, Little, Thrailkill & Owen, Nashville, Tenn., for petitioners-appellants.

M. Carr Ferguson, Donald B. Susswein, Asst. Atty. Gen., Gilbert E. Andrews, Crombie J. D., Garrett, Carleton D. Powell, Tax Division, U. S. Dept. of Justice, Washington, D. C., Stuart E. Seigel, Chief Counsel, Internal Revenue Service, Washington, D. C. (Treas. Dept.), for respondent-appellee.

Before WEICK, CELEBREZZE and KEITH, Circuit Judges.

ORDER

This is an appeal from a decision of the United States Tax Court in favor of the Respondent, who had determined a deficiency of $66,244.28 in Petitioners' Federal Income Tax for the year 1969. Because of concessions made by Petitioners, only one issue remained for decision, namely, whether G-O Enterprises, Inc., a corporation in which Petitioner John R. Ozier was a stockholder, was eligible under Sections 1371 and 1372 of the Internal Revenue Code of 1954...

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