Dunlap v. Commissioner
United States Tax Court
Petitioner Dunlap, together with one Weil, were officers and shareholders of petitioner Hawkeye Bancorporation. Hawkeye wished to acquire the stock of Jasper Bank but required prior Federal Reserve Board (F.R.B.) approval, and the Jasper stockholders were unwilling to wait.
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Petitioner Dunlap, together with one Weil, were officers and shareholders of petitioner Hawkeye Bancorporation. Hawkeye wished to acquire the stock of Jasper Bank but required prior Federal Reserve Board (F.R.B.) approval, and the Jasper stockholders were unwilling to wait. Accordingly, Dunlap and Weil purchased the Jasper stock, most of it under an installment payment agreement, for a total price of $ 4,072,190, with Dunlap taking an 83.6-percent interest and concurrently with the purchase of the bulk of the stock, agreed with Hawkeye to resell all the stock to Hawkeye for $ 4,150,000 if and…
1Opinion of the Court
Hall, Judge:
Respondent determined the following income tax deficiencies and additions to tax:
Petitioners Sec. 6653(b)2 Docket No. Year Deficiency addition to tax
Paul D. Dunlap and Shirley A. Dunlap 2779-77 1971 $125,780 $62,890
6726-76 1972 289,709 144,855
5351-77 1973 40,914 20,457
Hawkeye Bancorporation 2414-77 1971 16,513 ---
7858-76 1972 523,915 ---
9438-77 1973 340,775 ---
In his amended answer in docket No. 5351-77 (Paul D. Dunlap and Shirley A. Dunlap), respondent asserts that the deficiency should be increased by $49,313 for a total deficiency of $90,227. In his amended answer in docket No.…
2Cases cited28 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. BrownSupreme Court of the United States · 1965
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
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3Cited by32 opinions
- Rice's Toyota World, Inc. v. CommissionerUnited States Tax Court · 1983
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- Gefen v. CommissionerUnited States Tax Court · 1986
- Midkiff v. CommissionerUnited States Tax Court · 1991
- Paul D. Dunlap and Shirley A. Dunlap, Hawkeye Bancorporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1982
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