Mogab v. Commissioner
United States Tax Court
London's sec. 1244 plan failed to specifically state, in terms of dollars, the maximum amount to be received for stock issued under the plan. Held, petitioner's London stock is not sec. 1244 stock and therefore petitioners are not entitled to an ordinary loss under sec. 1244, I.R.C. 1954, for their worthless stock. Sec. 1.1244(c)-1(c), Income Tax Regs., followed.
1Opinion of the Court
Wiles, Judge:
Respondent determined a $6,000 deficiency in petitioners’ 1972 income taxes. The only issue is whether petitioners’ loss on their London Beef House, Ltd., stock was a loss on section 12441 stock.
FINDINGS OF FACT
All facts have been stipulated and are found accordingly.
Petitioners Charles A. Mogab and Colleen Mogab, husband and wife, filed their 1972 joint Federal income tax return with the Internal Revenue Service Center, Kansas City, Mo. Petitioners were residents of Creve Coeur, Mo., when they filed their petition herein. Colleen Mogab is a party to this action solely because…
2Cases cited9 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Godart v. CommissionerUnited States Tax Court · 1969
- Spiegel v. CommissionerUnited States Tax Court · 1968
- Mance T. Spillers and Mary J. Spillers v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
4 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Malinowski v. CommissionerUnited States Tax Court · 1979
- Frantz v. CommissionerUnited States Tax Court · 1984
- Cosgrove v. CommissionerUnited States Tax Court · 1987
- Wong v. CommissionerUnited States Tax Court · 1994
- Cournan v. CommissionerUnited States Tax Court · 1989
5 more not listed; retrieve them via the Exa API.