Levin v. Commissioner
United States Tax Court
Stock owned by the petitioner and her brother was redeemed so that the petitioner's son became the sole stockholder. The petitioner remained a salaried employee of the corporation. Held, the distributions in redemption of petitioner's stock were essentially equivalent to dividends within the meaning of sec. 302(b)(1), I.R.C. 1954.
1Opinion of the Court
Simpson, Judge:
In the notices of deficiency, respondent determined deficiencies in petitioner’s income tax of $1,015.22 for 1960, $1,037.74 for 1961, $970.04 for 1962, and $5,976.60 for 1963. By an amended answer in this proceeding, respondent asserted an increased deficiency of $8,642.39 for 1960; thus, the total deficiency determined for such year is $9,657.61.
The issues for decision are whether distributions in redemption of petitioner’s stock were essentially equivalent to dividends, and whether the respondent erroneously determined the amount of the corporate distributions to her in 1962…
2Cases cited16 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
- United States v. John H. FewellCourt of Appeals for the Fifth Circuit · 1958
- Eva D. Bradbury v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1962
- Lewis v. CommissionerUnited States Tax Court · 1960
11 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Metzger Trust v. CommissionerUnited States Tax Court · 1981
- Beatrice Levin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Estate of Lammerts v. CommissionerUnited States Tax Court · 1970
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Estate of Runnels v. CommissionerUnited States Tax Court · 1970
24 more not listed; retrieve them via the Exa API.