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CARUTH v. U.S.

Civ. A. No. 3-84-0877-R.

688 F.Supp. 1129 (1987)

W.W. and Mabel P. CARUTH, and Caruth Corporation, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Texas, Dallas Division.

October 20, 1987.

Attorney(s) appearing for the Case

Vester T. Hughes, Jr., David Sinak, David Kent, Cynthia Ohlenforst, Dallas, Tex., for plaintiffs.

Louise P. Hytken, Dept. of Justice, Dallas, Tex., for defendant.

MEMORANDUM OPINION

BUCHMEYER, District Judge.

This is an income tax case. It involves such exotic tax concepts as the "assignment of income" doctrine, the "economic realities" test, the "step-transaction" analysis, the business purpose requirement, and even an overworked horticultural metaphor.1

The plaintiffs are W.W. and Mabel Caruth. In 1978, they were majority stockholders in a closely held corporation, North Park...

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