Larry E. & Belinda Austin v. Commissioner

141 T.C. No. 18

UNITED STATES TAX COURT LARRY E. AUSTIN AND BELINDA AUSTIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent ESTATE OF ARTHUR E. KECHIJIAN, DECEASED, SUSAN P. KECHIJIAN AND SCOTT E. HOEHN, CO-EXECUTORS, AND SUSAN P. KECHIJIAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8966-10, 8967-10. Filed December 16, 2013. Ps exchanged property for ostensibly restricted stock of a newly formed S corporation (S). The governing agreements provided that Ps, upon termination of employment, would receive less than the full fair market value of their S…