Redding v. Commissioner
United States Tax Court
Petitioners were stockholders in Water Co. On Jan. 7, 1971, they received from Water Co. stock subscription rights, evidenced by transferable warrants, entitling them to purchase stock in Shorewood, a wholly owned subsidiary of Water Co., for less than its fair market value. The subscription period expired on Jan. 22, 1971, after which time the rights and warrants were totally worthless.
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Petitioners were stockholders in Water Co. On Jan. 7, 1971, they received from Water Co. stock subscription rights, evidenced by transferable warrants, entitling them to purchase stock in Shorewood, a wholly owned subsidiary of Water Co., for less than its fair market value. The subscription period expired on Jan. 22, 1971, after which time the rights and warrants were totally worthless. Petitioners exercised their rights during the subscription period, and after tendering their rights and the requisite cash consideration, on Feb. 2, 1971, the date of the stock distribution, received shares…
1Opinion of the Court
Gerald R. Redding and Dorothy M. Redding, Petitioners v. Commissioner of Internal Revenue, Respondent; Thomas W. Moses and Anne M. Moses, Petitioners v. Commissioner of Internal Revenue, Respondent
Redding v. Commissioner
Docket Nos. 5174-75, 5176-75
United States Tax Court
71 T.C. 597; 1979 U.S. Tax Ct. LEXIS 192;
January 22, 1979, Filed
Decisions will be entered for the petitioners.
Petitioners were stockholders in Water Co. On Jan. 7, 1971, they received from Water Co. stock subscription rights, evidenced by transferable warrants, entitling them to purchase stock in Shorewood, a wholly owned…
Also in this document: Dissent.
2Cases cited24 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. HallockSupreme Court of the United States · 1940
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Palmer v. CommissionerSupreme Court of the United States · 1937
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