Family Record Plan, Incorporated (Dissolved) v. Commissioner Of Internal Revenue

309 F.2d 208 FAMILY RECORD PLAN, INCORPORATED (Dissolved) and Family Record Plan, Incorporated, Transferee of Family Record Plan, Incorporated (Dissolved), Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 17563. United States Court of Appeals Ninth Circuit. October 22, 1962. Rehearing Denied November 29, 1962. Baird & Holley, Harold Easton, and Thomas A. Baird, Los Angeles, Cal., for petitioners. Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, and Norman H. Wolfe, Attorneys, Department of Justice, Washington, D. C., and Crane C. Hauser, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent. Before HAMLEY, MERRILL and DUNIWAY, Circuit Judges. DUNIWAY, Circuit Judge. 1 In this petition to review decisions of the Tax Court, the problem presented is strikingly similar to that dealt with by us in Commissioner of Internal Revenue v. Kuckenberg, 309 F.2d 202 , decided October 11, 1962. 2 Family Record Plan, Incorporated (dissolved), here referred to as Transferor, and Family Record Plan, Incorporated (formerly F.R.P., Inc.), here referred to as Transferee, are the petitioners. There is no substantial dispute as to the…