Legal Opinion

Fehrs Finance Co. v. Commissioner

United States Tax Court

Decided May 1, 1972No. Docket No. 2136-69Published

EF and VF, husband and wife, owned all the stock in R, a corporation. Within a period of about 3 months, (1) EF gave some of his stock to VF, and to their son-in-law, daughters, and grandchildren, (2) the petitioner was incorporated, with the daughters of EF and VF as the sole shareholders, (3) EF and VF transferred the remainder of their stock in R to the petitioner in return for the petitioner's promise to pay them lifetime annuities, and (4) the petitioner sold all of the…

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EF and VF, husband and wife, owned all the stock in R, a corporation. Within a period of about 3 months, (1) EF gave some of his stock to VF, and to their son-in-law, daughters, and grandchildren, (2) the petitioner was incorporated, with the daughters of EF and VF as the sole shareholders, (3) EF and VF transferred the remainder of their stock in R to the petitioner in return for the petitioner's promise to pay them lifetime annuities, and (4) the petitioner sold all of the stock so acquired to R, in exchange for cash and a note, and R canceled such stock. Held: (1) The transaction in which…

1Opinion of the Court

Fehrs Finance Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Fehrs Finance Co. v. Commissioner

Docket No. 2136-69

United States Tax Court

58 T.C. 174; 1972 U.S. Tax Ct. LEXIS 138;

May 1, 1972, Filed

Decision will be entered under Rule 50.

EF and VF, husband and wife, owned all the stock in R, a corporation. Within a period of about 3 months, (1) EF gave some of his stock to VF, and to their son-in-law, daughters, and grandchildren, (2) the petitioner was incorporated, with the daughters of EF and VF as the sole shareholders, (3) EF and VF transferred the remainder of their stock…

Also in this document: Concurrence · Tannenwald; Concurrence · Quealy.

2Cases cited37 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. United States v. DavisSupreme Court of the United States · 1970
  3. Peter Vaira and Mary L. Vaira v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
  4. Vaira v. CommissionerUnited States Tax Court · 1969
  5. Cary v. CommissionerUnited States Tax Court · 1963

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