United States v. Curtis L. Parker and Martha Parker

GOLDBERG, Circuit Judge:

The protesting and unhappy taxpayers, Curtis L. Parker and his wife, Martha, owned a wholesale and retail oil and gasoline business. On April 1, 1959, Parker and B. K. Eaves, a longtime employee, formed a Louisiana corporation incorporating Parker’s business. The corporation had an authorized capital stock of 1,000 shares.

Parker subscribed to 800 shares and paid for them by transferring to the corporation certain property valued at $93,-400.00 to be used in the corporation’s business. Eaves subscribed to the remaining 200 shares. He paid $7,500.00 cash and agreed to…