Legal Opinion

Estate of Glass v. Commissioner

United States Tax Court

Decided December 21, 1970No. Docket No. 1333-66PublishedCited by 32 opinions

Petitioner, president and owner of all issued stock of Fidelity, decided to retire and gave Skinner, a lawyer, an option to purchase all of his stock for $ 1,500,000. Skinner was unable to raise the necessary funds but arranged a transaction with another life insurance company, which when coupled with the sale of one-fourth of the stock to Skinner and the redemption by Fidelity of Glass' remaining shares, would result in payment to Glass of the option price.

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Petitioner, president and owner of all issued stock of Fidelity, decided to retire and gave Skinner, a lawyer, an option to purchase all of his stock for $ 1,500,000. Skinner was unable to raise the necessary funds but arranged a transaction with another life insurance company, which when coupled with the sale of one-fourth of the stock to Skinner and the redemption by Fidelity of Glass' remaining shares, would result in payment to Glass of the option price. On May 28, 1962, Fidelity, pursuant to Skinner's plan, executed a reinsurance agreement with United, also a life insurance company,…

1Opinion of the Court

Hoyt, Judge:

Respondent determined the following deficiencies and addition to tax were due from Fidelity Service Insurance Co.:

Deficiency

Delinquency TYE~- Income tax penalty, sec. 6661

12/31/60_ $124. 17-

12/31/61. — _ 177,431.41 -

12/31/62_ 983,727.80 $245,931.95

Respondent further determined that the petitioner’s decedent was liable for the above amounts as a transferee in equity of the assets of Fidelity.

Petitioner concedes the respondent’s determination with respect to the taxable year ended December 31, 1960. The issues remaining for our determination are as follows:(1) Whether the transfer…

2Cases cited15 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Phillips v. CommissionerSupreme Court of the United States · 1931
  3. Northern Pacific Railway Co. v. BoydSupreme Court of the United States · 1913
  4. Pierce v. United StatesSupreme Court of the United States · 1921
  5. Kreps v. CommissionerUnited States Tax Court · 1964

10 more not listed; retrieve them via the Exa API.

3Cited by32 opinions

  1. Crown v. CommissionerUnited States Tax Court · 1981
  2. Yoc Heating Corp. v. CommissionerUnited States Tax Court · 1973
  3. Alexander v. CommissionerUnited States Tax Court · 1973
  4. Merriam v. CommissionerUnited States Tax Court · 1995
  5. Stansbury v. CommissionerUnited States Tax Court · 1995

27 more not listed; retrieve them via the Exa API.

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