Owens v. Commissioner
United States Tax Court
Held, petitioner's sale in 1965 of all of his stock in his wholly owned subch. S corporation was not a bona fide arm's-length transaction and petitioner is taxable on the undistributed subch.
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Held, petitioner's sale in 1965 of all of his stock in his wholly owned subch. S corporation was not a bona fide arm's-length transaction and petitioner is taxable on the undistributed subch. S income of the corporation in the taxable year of sale; held, further, petitioner has not overcome respondent's prima facie case that he is a transferee within the meaning of sec. 6901, I.R.C. 1954, and thus is liable for any deficiency in income tax of the corporation for its 1964 taxable year, when it was not a subch. S corporation; held, further, the major portion of payments made by the corporation…
1Opinion of the Court
E. Keith Owens, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent; E. Keith Owens and Sharon E. Owens, Petitioners v. Commissioner of Internal Revenue, Respondent
Owens v. Commissioner
Docket Nos. 1947-70, 1988-70
United States Tax Court
64 T.C. 1; 1975 U.S. Tax Ct. LEXIS 167;
April 2, 1975, Filed
Decisions will be entered under Rule 155.
Held, petitioner's sale in 1965 of all of his stock in his wholly owned subch. S corporation was not a bona fide arm's-length transaction and petitioner is taxable on the undistributed subch. S income of the corporation in the taxable year of…
Also in this document: Dissent · Fay; Dissent · Irwin.
2Cases cited35 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
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