Dogali v. Commissioner
United States Tax Court
Petitioner husband (P), a neurosurgeon, was employed by Dr. S. Dr. S subsequently incorporated his practice and named it N. Corp. P and others purchased control of N Corp. from Dr. S. Each buyer purchased one share; the remaining shares were redeemed by N Corp. N Corp. gave Dr. S cash and a promissory note (the note) in consideration for the stock redeemed. P guaranteed a portion of the note.
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Petitioner husband (P), a neurosurgeon, was employed by Dr. S. Dr. S subsequently incorporated his practice and named it N. Corp. P and others purchased control of N Corp. from Dr. S. Each buyer purchased one share; the remaining shares were redeemed by N Corp. N Corp. gave Dr. S cash and a promissory note (the note) in consideration for the stock redeemed. P guaranteed a portion of the note. N Corp. entered into an employment agreement with Dr. S (the S agreement). P guaranteed a portion of the payments to be made under the S agreement. P left the employ of N Corp. and formed his own…
1Opinion of the Court
MICHAEL AND JEANNE A. DOGALI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dogali v. Commissioner
Docket Nos. 3405-92, 24906-92
United States Tax Court
T.C. Memo 1995-39; 1995 Tax Ct. Memo LEXIS 54; 69 T.C.M. (CCH) 1759;
January 30, 1995, Filed
Decisions will be entered under Rule 155.
Petitioner husband (P), a neurosurgeon, was employed by Dr. S. Dr. S subsequently incorporated his practice and named it N. Corp. P and others purchased control of N Corp. from Dr. S. Each buyer purchased one share; the remaining shares were redeemed by N Corp. N Corp. gave Dr. S cash and a promissory…
2Cases cited21 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Neely v. CommissionerUnited States Tax Court · 1985
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- United States v. GilmoreSupreme Court of the United States · 1963
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