Legal Opinion

Stiefel v. Commissioner

United States Tax Court

Decided October 3, 1947No. Docket No. 11713Published

Petitioner and his wife acquired all of the capital stock of a corporation which owned and operated a mercantile business. Stock certificates were written, but not executed, which indicated that if they had been executed as written petitioner owned 99 per cent and his wife 1 per cent of the stock. The stock was purchased with funds contributed in substantial amounts by each of the spouses under an agreement between them that each should own one-half thereof.

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Petitioner and his wife acquired all of the capital stock of a corporation which owned and operated a mercantile business. Stock certificates were written, but not executed, which indicated that if they had been executed as written petitioner owned 99 per cent and his wife 1 per cent of the stock. The stock was purchased with funds contributed in substantial amounts by each of the spouses under an agreement between them that each should own one-half thereof. The spouses each rendered full time and valuable services in the operation of the corporation's business. The corporation was later…

1Opinion of the Court

Reuben Stiefel, Petitioner, v. Commissioner of Internal Revenue, Respondent

Stiefel v. Commissioner

Docket No. 11713

United States Tax Court

9 T.C. 576; 1947 U.S. Tax Ct. LEXIS 79;

October 3, 1947, Promulgated

Decision will be entered for petitioner.

Petitioner and his wife acquired all of the capital stock of a corporation which owned and operated a mercantile business. Stock certificates were written, but not executed, which indicated that if they had been executed as written petitioner owned 99 per cent and his wife 1 per cent of the stock. The stock was purchased with funds contributed in…

2Cases cited2 opinions

  1. Canfield v. CommissionerUnited States Tax Court · 1946
  2. Stiefel v. CommissionerUnited States Tax Court · 1947

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