Piggy Bank Stations, Inc. v. Commissioner of Internal Revenue

GEE, Circuit Judge:

Piggy Bank Stations, Inc. (Stations) and Piggy Bank, Inc. brought an action in the United States Tax Court contesting the assertion of income tax deficiencies against them by the Commissioner of Internal Revenue (the “Commissioner”). The tax court held for the Commissioner. We affirm.

I

Sam S. Klink and William Johnstone owned equal shares of two affiliated corporations, Piggy Bank Land, Inc. (Land) and Stations. Stations operated gasoline stations and owned some of the stations it operated. Land owned and leased other filling stations to Stations, and still other filling…