Hurst v. Comm'r
United States Tax Court
In 1997, as part of their retirement planning, Ps sold their stock in R Corp. to H Corp. H Corp. redeemed 90 percent of P- husband's stock in H Corp., and P-husband sold the remainder to his son and two third parties. Both the redemption and stock sales provided for payment over 15 years and were secured by the shares of stock being redeemed or sold.
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In 1997, as part of their retirement planning, Ps sold their stock in R Corp. to H Corp. H Corp. redeemed 90 percent of P- husband's stock in H Corp., and P-husband sold the remainder to his son and two third parties. Both the redemption and stock sales provided for payment over 15 years and were secured by the shares of stock being redeemed or sold. Ps continued to own H Corp.'s headquarters building, which they leased back to H Corp. P-wife continued to be an employee of H Corp. after the redemption, and she and her husband continued to receive medical insurance through her employment. All…
1Opinion of the Court
RICHARD E. AND MARY ANN HURST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hurst v. Comm'r
No. 15792-02
United States Tax Court
124 T.C. 16; 2005 U.S. Tax Ct. LEXIS 2; 124 T.C. No. 2;
February 3, 2005, Filed
Court did not rule against petitioners on section 304 question. Cost of petitioner's medical insurance were taxable to her, subject to deduction for percentage of health insurance premiums that Hurst Mechanical, Inc. paid on her behalf. Penalty against petitioners was not sustained.
In 1997, as part of their retirement planning, Ps sold their
stock in R Corp. to H Corp. H Corp.…
2Cases cited19 opinions
- Dunn v. CommissionerUnited States Tax Court · 1978
- Herbert A. Dunn and Georgia E. Dunn v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
- Shea v. CommissionerUnited States Tax Court · 1999
- United States v. DavisSupreme Court of the United States · 1970
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
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