Lisle v. Commissioner
United States Tax Court
Corporate petitioner purchased all the stock of its two principal shareholders under agreements providing for down payments and deferred payments extending over 20 years. The individuals retained right to vote, their membership on the board of directors and their positions as officers, although they received no compensation therefor and did not actively participate in the management of the corporation.
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Corporate petitioner purchased all the stock of its two principal shareholders under agreements providing for down payments and deferred payments extending over 20 years. The individuals retained right to vote, their membership on the board of directors and their positions as officers, although they received no compensation therefor and did not actively participate in the management of the corporation. Held: The 20-year payout period does not perse prevent the sale from qualifying as a redemption under Sec. 302(b)(3), I.R.C. 1954. The right to vote served merely as additional security for…
1Opinion of the Court
CLAUDE J. LISLE and VI LISLE, ET AL 1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lisle v. Commissioner
Docket Nos. 1760-73, 1849-73, 1851-73, 1852-73
United States Tax Court
T.C. Memo 1976-140; 1976 Tax Ct. Memo LEXIS 263; 35 T.C.M. (CCH) 627; T.C.M. (RIA) 760140;
May 4, 1976, Filed
Corporate petitioner purchased all the stock of its two principal shareholders under agreements providing for down payments and deferred payments extending over 20 years. The individuals retained right to vote, their membership on the board of directors and their positions as officers, although they…
2Cases cited39 opinions
- California Lettuce Growers, Inc. v. Union Sugar Co.California Supreme Court · 1955
- United States v. DavisSupreme Court of the United States · 1970
- Dean v. CommissionerUnited States Tax Court · 1961
- Merrill v. CommissionerUnited States Tax Court · 1963
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
34 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
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- Barton Theatre Company, an Oklahoma Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1983