Stephens v. Commissioner
United States Tax Court
Our Own Deliveries, Inc., a subchapter S corporation, agreed to redeem the stock of two shareholders with payment of 10 percent of the redemption price upon delivery of the stock and the balance over a period of approximately 1 year from the date the stock was delivered.
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Our Own Deliveries, Inc., a subchapter S corporation, agreed to redeem the stock of two shareholders with payment of 10 percent of the redemption price upon delivery of the stock and the balance over a period of approximately 1 year from the date the stock was delivered. Petitioners, who were also shareholders of Our Own Deliveries, Inc., entered into a binding contract to purchase the stock of the remaining shareholder and after this agreement was entered into payment for this shareholder's stock was made by the corporation. Held, the payment by the corporation of petitioners' obligation…
1Opinion of the Court
Scott, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income tax:
Docket No. Petitioners Year Deficiencies 2960-70...Thomas C. and Margaret N. Stephens.. 2901-70 — .Taylor A. and Judith K. Stephens_ 1967 1967 $32,028.37 29,481.87
The issue for decision is whether petitioners received dividend income when their corporation, Our Own Deliveries, Inc., redeemed the stock of shareholder Joseph G. Thornbury, Jr., and, if so, the amount of the dividend income received.
BINDINGS OP PACT
Some of the facts have been stipulated and are found accordingly.
Thomas C. Stephens and…
2Cases cited11 opinions
- Enoch v. CommissionerUnited States Tax Court · 1972
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- William J. Sullivan and Georgia K. Sullivan v. United StatesCourt of Appeals for the Eighth Circuit · 1966
- Fox v. HarrisonCourt of Appeals for the Seventh Circuit · 1944
6 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Coleman v. CommissionerUnited States Tax Court · 1986
- Smith v. CommissionerUnited States Tax Court · 1978
- Estate of Durkin v. CommissionerUnited States Tax Court · 1992
- Illinois Power Co. v. CommissionerUnited States Tax Court · 1986
- Hayes v. CommissionerUnited States Tax Court · 1993
23 more not listed; retrieve them via the Exa API.