Legal Opinion

Hodous v. Commissioner

United States Tax Court

Decided June 28, 1950No. Docket No. 16670Published

Between 1935 and 1943, petitioner entered into agreements with stockholders of a corporation holding defaulted farm mortgages. The agreements provided that the stockholders would endorse their shares in blank and give them to petitioner for the purpose of compelling the management of the corporation to liquidate. If successful, petitioner was to receive a percentage of the amounts paid to the shareholders in liquidation.

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Between 1935 and 1943, petitioner entered into agreements with stockholders of a corporation holding defaulted farm mortgages. The agreements provided that the stockholders would endorse their shares in blank and give them to petitioner for the purpose of compelling the management of the corporation to liquidate. If successful, petitioner was to receive a percentage of the amounts paid to the shareholders in liquidation. If unsuccessful, he was to return the shares to the stockholders. (1) The sums received by petitioner in 1943, 1944, and 1945 as the percentage of dividends in liquidation…

1Opinion of the Court

Frank Hodous, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hodous v. Commissioner

Docket No. 16670

United States Tax Court

14 T.C. 1301; 1950 U.S. Tax Ct. LEXIS 150;

June 28, 1950, Promulgated

Decision will be entered under Rule 50.

Between 1935 and 1943, petitioner entered into agreements with stockholders of a corporation holding defaulted farm mortgages. The agreements provided that the stockholders would endorse their shares in blank and give them to petitioner for the purpose of compelling the management of the corporation to liquidate. If successful, petitioner was to receive a…

2Cases cited3 opinions

  1. Belser v. CommissionerUnited States Tax Court · 1948
  2. Ansorge v. CommissionerUnited States Tax Court · 1943
  3. Hodous v. CommissionerUnited States Tax Court · 1950

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