Salyer Grain and Milling Company, Petitioner-appellant, v. Commissioner of Internal Revenue Service, Respondent-appellee

United States Court of Appeals, Ninth Circuit. - 815 F.2d 1265

Argued and Submitted April 17, 1987.Decided April 24, 1987

James E. Merritt, Washington, D.C., for petitioner-appellant.

David Pincus, Washington, D.C., for respondent-appellee.

Appeal from a Decision of the United States Tax Court.

Before GOODWIN, TANG and THOMPSON, Circuit Judges.

1

ORDER

2

The decision of the Tax Court is affirmed substantially for the reasons stated by the Tax Court in its opinion in T.C.Memo. 1986-165. We do not consider the appellant's argument concerning the tax consequences of stock options because the point was never raised in the Tax Court.