Missimer v. Commissioner
United States Tax Court
Certain of petitioners in docket No. 7221-75 transferred their controlling stock in a corporation to the petitioners in docket No. 6800-75. The sellers received $ 143,825 in cash from the buyer and the corporation transferred to the sellers real property and a building owned by it for $ 12,000 paid by the sellers to the corporation. The $ 12,000 was considerably less than the fair market value of the real property and building.
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Certain of petitioners in docket No. 7221-75 transferred their controlling stock in a corporation to the petitioners in docket No. 6800-75. The sellers received $ 143,825 in cash from the buyer and the corporation transferred to the sellers real property and a building owned by it for $ 12,000 paid by the sellers to the corporation. The $ 12,000 was considerably less than the fair market value of the real property and building. Held, based on the transaction as a whole, the excess value of the real property and building over the sale price thereof was a constructive dividend to the buyer of…
1Opinion of the Court
CHARLES D. MISSIMER AND BETTY MISSIMER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; J. ARMSTRONG CROSS AND ESTATE OF JUDITH A. CROSS, DECEASED, J. ARMSTRONG CROSS AND KATHERINE A. BURKE, CO-EXECUTORS, and ESTATE OF RICHARD F. BURKE, DECEASED, KATHERINE A. BURKE, EXECUTRIX, AND KATHERINE A. BURKE, and KNOX L. CLARKE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Missimer v. Commissioner
Docket Nos. 6800-75, 7221-75.
United States Tax Court
T.C. Memo 1979-48; 1979 Tax Ct. Memo LEXIS 477; 38 T.C.M. (CCH) 192; T.C.M. (RIA) 79048;
February 7, 1979, Filed
Certain of…
2Cases cited7 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Christensen v. CommissionerUnited States Tax Court · 1959
- Gilmore v. CommissionerUnited States Tax Court · 1956
- Stephens v. CommissionerUnited States Tax Court · 1973
- West v. CommissionerUnited States Tax Court · 1962
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Mangurian v. CommissionerUnited States Tax Court · 1979