Greenfield v. Commissioner

BELL, Circuit Judge:

This suit arose after appellants Greenfield and Bugg were assessed $34,594.56 and $43,264 for claimed deficiencies with respect to 1964 income tax. The Commissioner grounded these assessments on two 1964 transactions which involved appellants and their wholly-owned corporations, Carline Electric Corporation [“Domestic”] and Carline, Ltd., [“Offshore”]. The Tax Court sustained the Commissioner’s contention that the two transactions involved investments by a controlled foreign corporation in United states property resulting in pro rata inclusion in the gross incomes of the…