Anderson v. Comm'r
United States Tax Court
A, the sole shareholder of corporation D, caused D to distribute to him in November 1978 substantially appreciated stock in a public corporation which was being held as collateral for D's debts to bank B. D's debts were also secured by the continuing guarantee of A. As part of the distribution, B agreed to release the stock from collateral but required that A, in his individual capacity, promise not to sell the stock until the outstanding balance of D's debts had been…
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A, the sole shareholder of corporation D, caused D to distribute to him in November 1978 substantially appreciated stock in a public corporation which was being held as collateral for D's debts to bank B. D's debts were also secured by the continuing guarantee of A. As part of the distribution, B agreed to release the stock from collateral but required that A, in his individual capacity, promise not to sell the stock until the outstanding balance of D's debts had been reduced. D was not liquidated following the distribution. B was given custody of the stock after it was retitled in A's name.…
1Opinion of the Court
Scott, Judge:
Respondent determined a deficiency in the Federal income tax of petitioners Robert O. Anderson and Barbara P. Anderson for their tax year ending October 31, 1977, in the amount of $104,263, and for their tax year ending October 31, 1979, in the amount of $3,059,563. Respondent determined a deficiency in the Federal income taxes of petitioner, the Hondo Co., for its tax year ending December 31, 1979, in the amount of $1,795,673.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision (1) whether the Hondo Co.…
2Cases cited29 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Burnet v. HarmelSupreme Court of the United States · 1932
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Pacific Gas & Electric Co. v. G. W. Thomas Drayage & Rigging Co.California Supreme Court · 1968
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3Cited by6 opinions
- Steiner v. CommissionerUnited States Tax Court · 1995
- Anderson v. Comm'rUnited States Tax Court · 1989
- Estate of Smith v. CommissionerUnited States Tax Court · 1989
- PRECISION PINE & TIMBER, INC. v. COMMISSIONERUnited States Tax Court · 2003
- Rollins v. CommissionerUnited States Tax Court · 1993
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