Jay F. Walker and Beatrice Walker v. Commissioner of Internal Revenue, Jay F. Walker and Beatrice Walker v. Commissioner of Internal Revenue, Newell E. Fait and Helen B. Fait v. Commissioner of Internal Revenue

544 F.2d 419 76-2 USTC P 9759 Jay F. WALKER and Beatrice Walker, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant. Jay F. WALKER and Beatrice Walker, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Newell E. FAIT and Helen B. Fait, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Nos. 74-1280, 74-1314, 74-1187. United States Court of Appeals, Ninth Circuit. Oct. 22, 1976. James E. Murphy (argued), of Gibson, Dunn & Crutcher, Los Angeles, Cal., for Newell Fait and Helen Fait. Frank DeMarco (argued), of DeMarco, Beral, Greenberg, Thrall & Slusher, Robert L. Weiner (argued), of Weiner & Rotman, Los Angeles, Cal., for Jay and Beatrice Walker. Ann B. Durney, Atty. (argued), of Tax Div., U.S. Dept. of Justice, Washington, D.C., for C. I. R. Before CARTER, TRASK and GOODWIN, Circuit Judges. TRASK, Circuit Judge: 1 Multiple appeals have arisen here from the determinations by the United States Tax Court of the tax liability of a buyer and a seller of corporate stock. The sale took place almost contemporaneously with a distribution of funds as dividends on the stock. Deficiencies were determined in the income taxes due from both buyer and seller.…