Legal Opinion

Hayes v. Commissioner

United States Tax Court

Decided December 29, 1993No. Docket Nos. 26913-91, 30646-91Published

On April 2, 1986, H and W entered into a separation agreement which provided that H would purchase W's stock in J, a corporation of which they were the sole stockholders. On June 4, 1986, an Ohio court entered a judgment of divorce with respect to H and W which incorporated their separation agreement, including the provision obligating H to purchase W's stock in J. On the same day, W and J executed an agreement in which J agreed to redeem W's stock.

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On April 2, 1986, H and W entered into a separation agreement which provided that H would purchase W's stock in J, a corporation of which they were the sole stockholders. On June 4, 1986, an Ohio court entered a judgment of divorce with respect to H and W which incorporated their separation agreement, including the provision obligating H to purchase W's stock in J. On the same day, W and J executed an agreement in which J agreed to redeem W's stock. J made one payment in redemption of W's stock on December 31, 1986, and a final payment on March 31, 1987. On March 3, 1987, the Ohio court which…

1Opinion of the Court

MARY RUTH HAYES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JIMMY L. HAYES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hayes v. Commissioner

Docket Nos. 26913-91, 30646-91

United States Tax Court

101 T.C. 593; 1993 U.S. Tax Ct. LEXIS 91; 101 T.C. No. 40;

December 29, 1993, Filed

On April 2, 1986, H and W entered into a separation agreement which provided that H would purchase W's stock in J, a corporation of which they were the sole stockholders. On June 4, 1986, an Ohio court entered a judgment of divorce with respect to H and W which incorporated their separation…

2Cases cited35 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Morgan v. CommissionerSupreme Court of the United States · 1940
  3. Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
  4. William J. Sullivan and Georgia K. Sullivan v. United StatesCourt of Appeals for the Eighth Circuit · 1966
  5. Webb v. Western Reserve Bond & Share Co.Ohio Supreme Court · 1926

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