Erickson v. Commissioner
United States Tax Court
Gordon Erickson and Mid-States Construction Co., a subchapter S corporation, entered into a written agreement in 1965 providing for the redemption of Erickson's 250 shares of stock for a redemption price of $ 146,479, with an upward or downward adjustment of the price depending upon whether the final profits of one construction job then in process were more or less than the amount estimated at the time of the agreement.
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Gordon Erickson and Mid-States Construction Co., a subchapter S corporation, entered into a written agreement in 1965 providing for the redemption of Erickson's 250 shares of stock for a redemption price of $ 146,479, with an upward or downward adjustment of the price depending upon whether the final profits of one construction job then in process were more or less than the amount estimated at the time of the agreement. The profits actually exceeded those estimated, and Erickson's share of the additional profits was an agreed-upon $ 9,000, making a total redemption price of $ 155,479. Held,…
1Opinion of the Court
Dawson, Judge:
In these consolidated cases respondent determined the following Federal income tax deficiencies:
Petitioners Pocket No, Year Peficiency
Gordon A. and Olive L. Erickson_ 684-70 1965 $8, 415. 69
W. Wayne and Pauline E. Skinner_ 956-70 1965 16, 631. 88
In docket No. 684-70 certain uncontested adjustments can be given effect in the Rule 50 computation.. The controversy in these proceedings arises out of an agreement dated April 12, 1965, between Gordon A. Erickson and Mid-States Construction Co., a subchaptor S corporation, providing for the redemption of Erickson’s stock for a…
2Cases cited8 opinions
- Podell v. CommissionerUnited States Tax Court · 1970
- A. G. Attebury Et Ux. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- S. & M. Plumbing Co. v. CommissionerUnited States Tax Court · 1971
- Natco Corporation, Formerly National Fireproofing Corporation v. United StatesCourt of Appeals for the Third Circuit · 1956
- Roesel v. CommissionerUnited States Tax Court · 1971
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Baldarelli v. CommissionerUnited States Tax Court · 1973
- Steffen v. CommissionerUnited States Tax Court · 1978
- Estate of Robert E. Cartwright, Deceased, Dorothy G. Cartwright v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Estate of Bette v. CommissionerUnited States Tax Court · 1977
- Baldarelli v. CommissionerUnited States Tax Court · 1973
4 more not listed; retrieve them via the Exa API.