Godart v. Commissioner
United States Tax Court
Petitioner, Pierre Godart, was an organizer and stockholder of FAB Corp. whose stock became worthless in 1962. He alleged in his petition that he should be allowed an ordinary loss on the ground that stock in FAB qualified as sec. 1244 stock.
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Petitioner, Pierre Godart, was an organizer and stockholder of FAB Corp. whose stock became worthless in 1962. He alleged in his petition that he should be allowed an ordinary loss on the ground that stock in FAB qualified as sec. 1244 stock. Held, the stock did not qualify under the statute and regulations as sec. 1244 stock in that the stock (1) was not issued pursuant to a written plan in which the period of the offering was specified to end in 2 years or less, (2) was not issued pursuant to a plan that specifically stated in terms of dollars the maximum amount to be received by the…
1Opinion of the Court
MulRONey, Judge:
Respondent determined a deficiency in petitioners’ income tax for the year 1962 in the amount of $46,557.28. After certain concessions made by the parties, the sole issue left for decision is whether the admitted loss petitioners suffered when certain stock became worthless in 1962 was a loss on “section 1244 stock.”
FINDINGS OF FACT
Some of the facts have been stipulated and they are found accordingly.
Pierre Godart, who will be called petitioner, and Suzanne Godart were husband and wife. They had their legal residence in New York, N.Y., at the time they filed the petition in…
2Cases cited4 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Spiegel v. CommissionerUnited States Tax Court · 1968
- Warner v. CommissionerUnited States Tax Court · 1967
- James A. And Audrey J. Warner v. Commissioner of Internal Revenue, Jerrie D. And Leta J. Schooley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
3Cited by27 opinions
- Malinowski v. CommissionerUnited States Tax Court · 1979
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Hayden v. CommissionerUnited States Tax Court · 1969
- Rickey v. CommissionerUnited States Tax Court · 1970
- Frantz v. CommissionerUnited States Tax Court · 1984
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