Estate of Schneider v. Commissioner
United States Tax Court
X, a corporation controlled by A, was a holding company for a group of affiliated corporations. X established a stock bonus plan, pursuant to which employees of the affiliated corporations could elect to use some or all of their cash bonuses to "purchase" Class B nonvoting stock from A. For each employee who elected to receive stock, corporation Y, a wholly owned subsidiary of X, issued two checks.
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X, a corporation controlled by A, was a holding company for a group of affiliated corporations. X established a stock bonus plan, pursuant to which employees of the affiliated corporations could elect to use some or all of their cash bonuses to "purchase" Class B nonvoting stock from A. For each employee who elected to receive stock, corporation Y, a wholly owned subsidiary of X, issued two checks. One check represented the cash portion of the bonus, net of withholding taxes; the other check represented the book value of the shares that the employee elected to purchase from A. This latter…
1Opinion of the Court
Estate of Al J. Schneider, Donald J. Schneider, et al., Personal Representatives, and Agnes Schneider, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Schneider v. Commissioner
Docket No. 6234-79
United States Tax Court
88 T.C. 906; 1987 U.S. Tax Ct. LEXIS 50; 88 T.C. No. 50;
April 15, 1987. April 15, 1987, Filed
Decision will be entered under Rule 155.
X, a corporation controlled by A, was a holding company for a group of affiliated corporations. X established a stock bonus plan, pursuant to which employees of the affiliated corporations could elect to use some or all of their…
2Cases cited19 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- United States v. IshamSupreme Court of the United States · 1873
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