AMC Trust, J.O. Haney, Jr., J.O. Haney, III and Patricia A. Haney Trustees, et al. - Page 22

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          Conclusion                                                                  
               After considering the factors set forth in our prior cases             
          and discussed in the briefs of the parties, we conclude that AMC            
          Trust, Oliver & Co., Blanco Springs, and Jopah were shams,                  
          lacking economic substance, and are to be disregarded for Federal           
          income tax purposes.  The net income of the asphalt business is             
          properly taxable to the Haneys.  We need not consider                       
          respondent’s alternative arguments that would lead to the same              
          result.                                                                     
               To reflect the foregoing and to eliminate “whipsaw”                    
          determinations made against the trusts,                                     

                                                  Decisions will be entered           
                                             under Rule 155.                          

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