Legal Opinion

Gadd v. Commissioner

United States Tax Court

Decided July 25, 1983No. Docket No. 6297-77Unpublished

Held: Petitioners received income from promoters' shares before 1973. They did not receive income, as respondent determined, in 1973 when permanent stock certificates were distributed.

1Opinion of the Court

L. DAMON GADD and SARA R. GADD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Gadd v. Commissioner

Docket No. 6297-77

United States Tax Court

T.C. Memo 1983-425; 1983 Tax Ct. Memo LEXIS 354; 46 T.C.M. (CCH) 815; T.C.M. (RIA) 83425;

July 25, 1983.

Held: Petitioners received income from promoters' shares before 1973. They did not receive income, as respondent determined, in 1973 when permanent stock certificates were distributed.

Martin D. Cohen, for the petitioners.

Arthur H. Boelter, and Alan I. Appel, for the respondent.

CHABOT

MEMORANDUM FINDINGS OF FACT AND OPINION

CHABOT, Judge:…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Foster v. Comm'rUnited States Tax Court · 1983
  3. LTV Corp. v. CommissionerUnited States Tax Court · 1975
  4. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  5. O'Neil v. CommissionerUnited States Tax Court · 1976

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