Pacific Coast Music Jobbers, Inc. v. Commissioner
United States Tax Court
Petitioner Charles H. Hansen entered into agreements on Nov. 23, 1962, to purchase all the stock of petitioner Pacific Coast Music Jobbers, Inc., whereby the sellers would receive $ 25,000 plus guaranteed dividends of a fixed amount over a 5-year period during which the stock of Pacific would be held in escrow.
Read the full summary
Petitioner Charles H. Hansen entered into agreements on Nov. 23, 1962, to purchase all the stock of petitioner Pacific Coast Music Jobbers, Inc., whereby the sellers would receive $ 25,000 plus guaranteed dividends of a fixed amount over a 5-year period during which the stock of Pacific would be held in escrow. Held, Hansen became a shareholder of Pacific on Nov. 23, 1962, and his failure to consent to Pacific's election under sec. 1372 not to be subject to tax caused a termination of that election. Held, further, dividends distributed in 1964 to the sellers on account of the stock of Pacific…
1Opinion of the Court
Sterrett, Judge:
The respondent determined a deficiency in the Federal income taxes of the petitioner Pacific Coast Music Jobbers, Inc., of $4,605.28 and $6,769.09 for its taxable years ending August 31, 1963, and August 31,1964, respectively. A deficiency of $11,419.89 was also determined by respondent in the Federal income taxes of the petitioners Charles H. Hansen and Isabel Hansen for the taxable year ended December 31,1964.
We have before us two issues for consideration. We are first to determine whether petitioner Pacific Coast Music Jobbers’, Inc.’s election to be treated as a small…
2Cases cited19 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner of Internal Revenue v. Union Pac. R. Co.Court of Appeals for the Second Circuit · 1936
- Merrill v. CommissionerUnited States Tax Court · 1963
- Kean v. CommissionerUnited States Tax Court · 1968
- Monroe Zipp and Helen Zipp v. Commissioner of Internal Revenue, Bernard Zipp and Jean B. Zipp v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
14 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Baird v. CommissionerUnited States Tax Court · 1977
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Derr v. CommissionerUnited States Tax Court · 1981
- Danenberg v. CommissionerUnited States Tax Court · 1979
- Pacific Coast Music Jobbers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
38 more not listed; retrieve them via the Exa API.