Palmer v. Commissioner
United States Tax Court
1. Palmer College was owned and operated by a profit-making corporation. The assets of the college comprised approximately 80 percent of the assets of the corporation. Approximately 70 percent of the outstanding shares of the corporation stock was owned by a trust of which the petitioner was trustee and income beneficiary. The remaining shares were owned outright by the petitioner.
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1. Palmer College was owned and operated by a profit-making corporation. The assets of the college comprised approximately 80 percent of the assets of the corporation. Approximately 70 percent of the outstanding shares of the corporation stock was owned by a trust of which the petitioner was trustee and income beneficiary. The remaining shares were owned outright by the petitioner. On Aug. 31, 1966, a charitable organization, of which the petitioner was controlling trustee, purchased the shares owned by the trust. On the same day, the petitioner contributed enough shares to the foundation so…
1Opinion of the Court
Simpson, Judge:
The respondent determined a deficiency of $178,809.72 in the Federal income tax of the petitioners for the year 1966. Two issues are presented for decision. The first is whether in substance, as well as in form, a contribution of stock by the petitioners preceded the redemption of such stock, when the redemption took place the very next day. In the event we find that the contribution, in substance, preceded the redemption, we must determine whether the fair market value of the stock was less than claimed by the petitioners in their return.
FINDINGS 05’ PACT
Some of the facts have…
2Cases cited74 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
69 more not listed; retrieve them via the Exa API.
3Cited by93 opinions
- Waddell v. CommissionerUnited States Tax Court · 1986
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Daniel D. And Agnes H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
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