Paul E. And Ruth v. Puckett v. Commissioner of Internal Revenue

COLEMAN, Circuit Judge.

The issue involved in this appeal has been quite clearly and succinctly stated by the Commissioner in his suggestion that this case be heard by the Court en banc, as follows (footnotes omitted):

“The issue involved in this appeal generally concerns the Subchapter S status of a finance company (here, First Finance Corporation (Finance)), of which appellee Paul E. Puckett (Puckett) was a 50 percent shareholder during the years in issue, under the Internal Revenue Code of 1954 (26 U.S.C.). More specifically, the issue involves whether the Subchapter S status of a finance…