Legal Opinion

Glacier State Electric Supply Co. v. Commissioner

United States Tax Court

Decided May 23, 1983No. Docket No. 4420-81Published

P is a corporation organized in 1946. P's shares were issued in effect one-half each to X and Y. Z, X, and Y organized a second corporation (GSB) in 1953. The stock of GSB was issued one-third to Z and two-thirds to P. These parties executed buy/sell agreements. After amendments in 1969, the agreements provided that one-half of the GSB shares held by P would be redeemed upon the death of X or Y and that all of Z's shares would be redeemed upon Z's death.

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P is a corporation organized in 1946. P's shares were issued in effect one-half each to X and Y. Z, X, and Y organized a second corporation (GSB) in 1953. The stock of GSB was issued one-third to Z and two-thirds to P. These parties executed buy/sell agreements. After amendments in 1969, the agreements provided that one-half of the GSB shares held by P would be redeemed upon the death of X or Y and that all of Z's shares would be redeemed upon Z's death. X died in 1976. Pursuant to the buy/sell agreements, two redemptions occurred. P received a check plus a 5-year note in return for one-half…

1Opinion of the Court

Glacier State Electric Supply Co., Petitioner v. Commissioner of Internal Revenue, Respondent

Glacier State Electric Supply Co. v. Commissioner

Docket No. 4420-81

United States Tax Court

80 T.C. 1047; 1983 U.S. Tax Ct. LEXIS 75; 80 T.C. No. 55;

May 23, 1983, Filed

Decision will be entered under Rule 155.

P is a corporation organized in 1946. P's shares were issued in effect one-half each to X and Y. Z, X, and Y organized a second corporation (GSB) in 1953. The stock of GSB was issued one-third to Z and two-thirds to P. These parties executed buy/sell agreements. After amendments in 1969, the…

2Cases cited27 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  4. United States v. DavisSupreme Court of the United States · 1970
  5. Foster v. Comm'rUnited States Tax Court · 1983

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