Uinta Livestock Corporation, a Wyoming Corporation v. United States

HILL, Circuit Judge.

This is an income tax refund suit to recover $88,330.27 of taxes paid for 1948. 1

The facts are largely undisputed. The Rees Land and Livestock Company, a large family owned corporation, conducted a sheep operation in Wyoming and a cattle operation in Utah. The sheep portion of the corporation comprised approximately 57% of the assets and was operated by William Rees and certain members of his family. 2 Por various reasons, it was decided to split the company. The idea conceived was for the William Rees group of shareholders to form a new corporation (Uinta) by transferring…