Zabolotny v. Commissioner
United States Tax Court
Petitioners owned a tract of land in North Dakota which they used for farming purposes. Oil was discovered under the land. Petitioners leased the mineral rights to Gulf Oil Corporation in return for sizable royalties. On May 20, 1981, petitioners incorporated their farming operation on the land. The corporation established an Employee Stock Ownership Plan (ESOP) for its employees.
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Petitioners owned a tract of land in North Dakota which they used for farming purposes. Oil was discovered under the land. Petitioners leased the mineral rights to Gulf Oil Corporation in return for sizable royalties. On May 20, 1981, petitioners incorporated their farming operation on the land. The corporation established an Employee Stock Ownership Plan (ESOP) for its employees. Petitioners then sold their initial interest in the land to the ESOP in exchange for payments to be received from a joint and survivor annuity plan established by the ESOP for the benefit of petitioners. Respondent…
1Opinion of the Court
ANTON ZABOLOTNY AND BERNEL ZABOLOTNY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Zabolotny v. Commissioner
Docket No. 4844-87
United States Tax Court
97 T.C. 385; 1991 U.S. Tax Ct. LEXIS 87; 97 T.C. No. 27;
September 30, 1991, Filed
Decision will be entered under Rule 155.
Petitioners owned a tract of land in North Dakota which they used for farming purposes. Oil was discovered under the land. Petitioners leased the mineral rights to Gulf Oil Corporation in return for sizable royalties. On May 20, 1981, petitioners incorporated their farming operation on the land. The corporation…
Also in this document: Dissent · Parr; Dissent · Ruwe; Dissent · Beghe.
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. BoyleSupreme Court of the United States · 1985
- American Tobacco Co. v. PattersonSupreme Court of the United States · 1982
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- Malat v. RiddellSupreme Court of the United States · 1966
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