Friedman And Jobusch, Architects And Engineers v. Commissioner Of Internal Revenue

627 F.2d 175 80-2 USTC P 9656 FRIEDMAN AND JOBUSCH, ARCHITECTS AND ENGINEERS, Bernard J. Friedman and Irma Friedman, Fred H. Jobusch and Josephine E. Jobusch, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Nos. 78-2016 to 78-2018. United States Court of Appeals, Ninth Circuit. Argued and Submitted July 8, 1980. Decided Sept. 4, 1980. Edward V. Lacambra, Schorr, Leonard & Felker, P.C., Tucson, Ariz., for petitioners-appellants. Gayle P. Miller, Atty., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee. Petition to Review a Decision of The Tax Court of the United States. Before CHOY, GOODWIN and FARRIS, Circuit Judges. FARRIS, Circuit Judge: 1 Friedman and Jobusch Architects and Engineers, Inc. and Bernard and Irma Friedman, individually, and Fred and Josephine Jobusch, individually, appeal from a decision by the United States Tax Court disqualifying from tax exempt status under I.R.C. § 501(a) a stock bonus trust created by the corporation. We affirm. 2 Petitioners Bernard Friedman and Fred Jobusch were principal shareholders and officers of petitioner corporation. In 1967 the corporation created a stock bonus plan…