Legal Opinion

Farha v. Commissioner

United States Tax Court

Decided June 26, 1972No. Docket Nos. 2358-70, 2359-70, 2360-70, 2361-70Published

Petitioners were shareholders of a corporation active in the production and sale of certain processed foods. They also were partners in a partnership which owned the land, the building, and certain other assets used by the corporation. On Aug. 19, 1967, petitioners agreed to sell substantially all of the partnership to Hormel.

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Petitioners were shareholders of a corporation active in the production and sale of certain processed foods. They also were partners in a partnership which owned the land, the building, and certain other assets used by the corporation. On Aug. 19, 1967, petitioners agreed to sell substantially all of the partnership to Hormel. On the same day in a separate agreement with Hormel, petitioners purportedly sold 80 percent of their stock in the corporation and Hormel purportedly agreed to effect, sometime within the following month, the redemption of petitioners' remaining 20 percent of stock.…

1Opinion of the Court

Chick M. Farha and Leenda Farha, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Farha v. Commissioner

Docket Nos. 2358-70, 2359-70, 2360-70, 2361-70

United States Tax Court

58 T.C. 526; 1972 U.S. Tax Ct. LEXIS 100;

June 26, 1972, Filed

Decisions will be entered for the respondent.

Petitioners were shareholders of a corporation active in the production and sale of certain processed foods. They also were partners in a partnership which owned the land, the building, and certain other assets used by the corporation. On Aug. 19, 1967, petitioners agreed to sell substantially all of…

2Cases cited16 opinions

  1. United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
  2. Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
  3. Williams v. McGowanCourt of Appeals for the Second Circuit · 1945
  4. C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1949
  5. Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951

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