Reddy v. Commissioner
United States Tax Court
Petitioners conditioned their preincorporation subscriptions for stock on the prospective corporation's adoption of a plan meeting the requirements of sec. 1244. Held: The stock subscribed for did not issue until the plan was adopted. Accordingly, petitioners are entitled to ordinary loss treatment under sec. 1244 when the stock became worthless during the year in issue.
1Opinion of the Court
John J. and Margaret C. Reddy, Petitioners v. Commissioner of Internal Revenue, Respondent
Reddy v. Commissioner
Docket No. 469-74
United States Tax Court
66 T.C. 335; 1976 U.S. Tax Ct. LEXIS 102;
May 24, 1976, Filed
Decision will be entered for the petitioners.
Petitioners conditioned their preincorporation subscriptions for stock on the prospective corporation's adoption of a plan meeting the requirements of sec. 1244. Held: The stock subscribed for did not issue until the plan was adopted. Accordingly, petitioners are entitled to ordinary loss treatment under sec. 1244 when the stock became…
2Cases cited3 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Hayden v. CommissionerUnited States Tax Court · 1969
- Reddy v. CommissionerUnited States Tax Court · 1976