Legal Opinion

Blount v. Commissioner

United States Tax Court

Decided March 26, 1969No. Docket No. 5519-66Published

The petitioner and his family owned 40 percent of the outstanding stock in a corporation; two other family groups, headed by his brother and brother-in-law, owned most of the balance of the stock.

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The petitioner and his family owned 40 percent of the outstanding stock in a corporation; two other family groups, headed by his brother and brother-in-law, owned most of the balance of the stock. The petitioner, his brother, and his brother-in-law entered into an agreement with the company, which provided for their retirement with a pension, and further provided that each of them could, at his election, have up to a certain stated amount of his stock redeemed by the corporation each year. This plan was not designed to effectuate any valid business purpose of the corporation. Held, the…

1Opinion of the Court

Howard P. Blount and Dolly H. Blount, Petitioners v. Commissioner of Internal Revenue, Respondent

Blount v. Commissioner

Docket No. 5519-66

United States Tax Court

51 T.C. 1023; 1969 U.S. Tax Ct. LEXIS 162;

March 26, 1969, Filed

Decision will be entered for the respondent.

The petitioner and his family owned 40 percent of the outstanding stock in a corporation; two other family groups, headed by his brother and brother-in-law, owned most of the balance of the stock. The petitioner, his brother, and his brother-in-law entered into an agreement with the company, which provided for their retirement…

2Cases cited12 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Eva D. Bradbury v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1962
  3. Decker v. CommissionerUnited States Tax Court · 1959
  4. Lewis v. CommissionerUnited States Tax Court · 1960
  5. Beatrice Levin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967

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