John P. Broadaway Teena G. Broadaway v. Commissioner of Internal Revenue, John M. Cameron Caroline D. Cameron v. Commissioner of Internal Revenue

BOWMAN, Circuit Judge.

John P. and Teena G. Broadaway and John M. and Caroline D. Cameron appeal from a final decision of the Tax Court 2 upholding the Commissioner’s assessment of tax deficiencies based on dividend distributions from Cameron Construction Company made to the Broadaways and the Camerons during the 1989 tax year. We affirm.

I

This case was submitted to the Tax Court on the basis of a fully stipulated record that provides the following salient facts. The Broadaways and the Camerons are shareholders in Cameron Construction Company (the Company) which operated and paid taxes as a…