Cerone v. Commissioner
United States Tax Court
P and his son were each 50 percent shareholders in C. Because of hostility between father and son, C redeemed all of P's stock therein. After the redemption, P continued to work as an employee of C for several years, but he retained no control over, and was not involved in the management of, the corporation after the redemption.
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P and his son were each 50 percent shareholders in C. Because of hostility between father and son, C redeemed all of P's stock therein. After the redemption, P continued to work as an employee of C for several years, but he retained no control over, and was not involved in the management of, the corporation after the redemption. Held, family hostility does not nullify the family attribution rules of sec. 318(a)(1), I.R.C. 1954, in determining whether the redemption satisfies the dividend equivalency test of sec. 302(b)(1), I.R.C. 1954, or the complete redemption test of sec. 302(b)(3), I.R.C.…
1Opinion of the Court
Michael N. Cerone and Helen E. Cerone, Petitioners v. Commissioner of Internal Revenue, Respondent; Stockade Cafe, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Cerone v. Commissioner
Docket Nos. 1683-80, 1684-80, 28696-81, 27979-82
United States Tax Court
87 T.C. 1; 1986 U.S. Tax Ct. LEXIS 86; 87 T.C. No. 1;
July 1, 1986, Filed
Decision will be entered for petitioners for the year 1974, and for respondent for the year 1976 in docket No. 1683-80.
Decisions will be entered for respondent in docket Nos. 1684-80, 28696-81, and 27979-82.
P and his son were each 50 percent shareholders…
2Cases cited30 opinions
- United States v. CalamaroSupreme Court of the United States · 1957
- United States v. DavisSupreme Court of the United States · 1970
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Blanche S. Benjamin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Haft Trust v. CommissionerUnited States Tax Court · 1974
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