Mogab v. Commissioner
United States Tax Court
London's sec. 1244 plan failed to specifically state, in terms of dollars, the maximum amount to be received for stock issued under the plan. Held, petitioner's London stock is not sec. 1244 stock and therefore petitioners are not entitled to an ordinary loss under sec. 1244, I.R.C. 1954, for their worthless stock. Sec. 1.1244(c)-1(c), Income Tax Regs., followed.
1Opinion of the Court
Charles A. Mogab and Colleen Mogab, Petitioners v. Commissioner of Internal Revenue, Respondent
Mogab v. Commissioner
Docket No. 8295-76
United States Tax Court
70 T.C. 208; 1978 U.S. Tax Ct. LEXIS 122;
May 15, 1978, Filed
Decision will be entered for the respondent.
London's sec. 1244 plan failed to specifically state, in terms of dollars, the maximum amount to be received for stock issued under the plan. Held, petitioner's London stock is not sec. 1244 stock and therefore petitioners are not entitled to an ordinary loss under sec. 1244, I.R.C. 1954, for their worthless stock. Sec. 1.1244(c)-1(c),…
2Cases cited10 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Godart v. CommissionerUnited States Tax Court · 1969
- Spiegel v. CommissionerUnited States Tax Court · 1968
- Mance T. Spillers and Mary J. Spillers v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
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