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its stock, 105 shares of which were issued to Eddy Ben Cordes.14
On March 14, 1983, Eddy Ben Cordes transferred 334 shares to Mrs.
Cordes. On January 14, 1994, Mrs. Cordes transferred 334 shares
back to Eddy Ben Cordes.
On CFC’s Schedule E, Compensation of Officers, to its 1992
and 1993 Forms 1120, CFC reported that Mrs. Cordes owned 33.4
percent and Jean Ann Richard owned 33.3 percent of its stock at
the end of 1992 and 1993.15 During his examination of CFC’s
taxable years 1988 through 1993, respondent determined that Mrs.
Cordes owned approximately one-third of CFC’s stock. On Schedule
E to its 1994 Form 1120, CFC reported that Eddy Ben Cordes owned
33.4 percent, John Cordes owned 33.3 percent, and Jean Ann
Richard owned 33.3 percent of its stock at the end of 1994.
B. Eddie Cordes, Inc., Stock Transfers
Eddie Cordes, Inc., initially issued 1,000 shares of stock
in January 1963--500 shares to Mr. Cordes, 400 shares to Mrs.
Cordes, and 100 shares to B.B. Journeycake. In January 1971,
B.B. Journeycake transferred 100 shares to Mr. Cordes. Also in
January 1971, Mrs. Cordes transferred 400 shares to Jean Ann
Richard. On March 29, 1983, Mr. Cordes transferred 600 shares to
14See supra note 7.
15CFC’s 1992 and 1993 Forms 1120 do not reveal who held
legal title to the remaining 33.3 percent of CFC stock during
those taxable years. We note, however, that Mr. Cordes did not
hold legal title to any shares of CFC during those taxable years.
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