Chertkof v. Commissioner
United States Tax Court
Held, fair market value of corporate distribution determined. Held, further, since petitioner acquired a prohibited interest within a 10-year period as defined in sec. 302(c)(2)(A), I.R.C. 1954, distribution taxable as ordinary dividend.
1Opinion of the Court
Wiles, Judge:
Respondent determined a deficiency of $229,390.71 in petitioners’ 1966 Federal income tax.1 The issues for decision are the fair market value of a corporate distribution to petitioner Jack Chertkof of an undivided one-third interest in real property in redemption of his stock in E & T Realty Co., and whether the redemption constituted a complete termination of his interest in the corporation within the meaning of section 302(b)(3)2 and the 10-year rule of section 302(c)(2)(A).
FINDINGS OF FACT
Some facts were stipulated and are found accordingly.
Jack 0. (hereinafter petitioner) and…
2Cases cited11 opinions
- United States v. DavisSupreme Court of the United States · 1970
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Robin Haft Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1975
- Makransky v. CommissionerUnited States Tax Court · 1961
6 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Whitehouse Hotel L.P. v. Comm'rUnited States Tax Court · 2008
- Jack O. Chertkof and Sophie Chertkof v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1981
- Cerone v. CommissionerUnited States Tax Court · 1986
- Whitehouse Hotel Ltd. P'ship v. Comm'rUnited States Tax Court · 2012
- Lynch v. CommissionerUnited States Tax Court · 1984
9 more not listed; retrieve them via the Exa API.