Legal Opinion

Dietzsch v. Commissioner

United States Tax Court

Decided March 31, 1976No. Docket No. 693-70Published

Petitioner entered into an agreement with GM for the financing of a corporate dealership. GM held the voting stock and petitioner held solely nonvoting stock. Petitioner received cash dividends in the taxable years 1965, 1966, and 1967 which, pursuant to agreement, petitioner was required to apply to the purchase of GM's stock.

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Petitioner entered into an agreement with GM for the financing of a corporate dealership. GM held the voting stock and petitioner held solely nonvoting stock. Petitioner received cash dividends in the taxable years 1965, 1966, and 1967 which, pursuant to agreement, petitioner was required to apply to the purchase of GM's stock. Petitioner was further required to convert that stock into additional nonvoting stock until such time as petitioner acquired all of the outstanding stock, which thereupon became voting stock. In a proceeding before the Court of Claims with respect to the taxable years…

1Opinion of the Court

William J. Dietzsch and Anita Dietzsch, Petitioners v. Commissioner of Internal Revenue, Respondent

Dietzsch v. Commissioner

Docket No. 693-70

United States Tax Court

65 T.C. 1172; 1976 U.S. Tax Ct. LEXIS 139;

March 31, 1976, Filed

Decision will be entered for the respondent.

Petitioner entered into an agreement with GM for the financing of a corporate dealership. GM held the voting stock and petitioner held solely nonvoting stock. Petitioner received cash dividends in the taxable years 1965, 1966, and 1967 which, pursuant to agreement, petitioner was required to apply to the purchase of GM's stock.…

2Cases cited4 opinions

  1. Dietzsch v. United StatesUnited States Court of Claims · 1974
  2. Richmond, F. & P. R. Co. v. CommissionerUnited States Tax Court · 1974
  3. Richmond, Fredericksburg and Potomac Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1975
  4. Dietzsch v. CommissionerUnited States Tax Court · 1976

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