Edward and Ruth Wilkof, Ervin and Marie Wilkof v. Commissioner of Internal Revenue

This is an appeal of a decision of the United States Tax Court entered December 14, 1978, reported at 47 T.C.M. 2072 (1978).

Taxpayers Edward and Ervin Wilkof are brothers. Since 1962 they have been co-owners of all the capital stock of Wilkof Structural Steel Corporation (WSS), each owning an equal one-half interest. The brothers have served as officers of WSS from the date of its incorporation in 1953. In 1968 the brothers, along with two cousins, formed a new corporation, TWM Manufacturing Company, Inc. (TWM). Shortly thereafter the shares of the cousins were redeemed and the two brothers…