Salyer Grain and Milling Company v. Commissioner of Internal Revenue Service

815 F.2d 1265

59 A.F.T.R.2d (RIA) 87-1033, 87-1 USTC P 9301

SALYER GRAIN AND MILLING COMPANY, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

No. 86-7445.

United States Court of Appeals,
Ninth Circuit.

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.

ORDER

1

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.