Legal Opinion

Michael Ferguson, Valene Ferguson, Roger N. Ferguson and Sybil Ferguson v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided April 7, 1999No. 98-70095PublishedCited by 11 opinions

1Opinion of the Court

CHOY, Circuit Judge:

Petitioners Michael and Valene Ferguson and Roger and Sybil Ferguson (“the Fergusons”), residents of Rexburg, Idaho, appeal the decision of the United States Tax Court, which concluded that the Fer-gusons could be taxed on the gain in appreciated stock that subsequently was transferred to various charitable organizations. See Ferguson v. Commissioner, 108 T.C. 244, 1997 WL 203699 (1997). The primary issue before us is whether the Tax Court correctly held that by the date that the transfer was completed, the stock already had ripened from an interest in a viable corporation…

2Cases cited12 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Kenneth Allen Barbara Allen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1991
  4. Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  5. Estate of E. W. Chism, Deceased, Clara Chism, and Clara Chism v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963

7 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. Rauenhorst v. Comm'rUnited States Tax Court · 2002
  2. CMA Consol., Inc. v. Comm'rUnited States Tax Court · 2005
  3. Benci-Woodward v. CommissionerCourt of Appeals for the Ninth Circuit · 2000
  4. Ivor F. Benci-Woodward and Debra A. Benci-Woodward v. Commissioner of Internal Revenue, Laurentz J. Mangum and Barbara Mangum v. Commissioner of Internal Revenue, Jose Ragatz and Dianne M. Ragatz v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
  5. The Pillsbury Co. v. Franchise Tax Bd.California Court of Appeal · 2004

6 more not listed; retrieve them via the Exa API.

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