Pacific Coast Music Jobbers, Inc. v. Commissioner
United States Tax Court
Petitioner Charles H. Hansen entered into agreements on Nov. 23, 1962, to purchase all the stock of petitioner Pacific Coast Music Jobbers, Inc., whereby the sellers would receive $ 25,000 plus guaranteed dividends of a fixed amount over a 5-year period during which the stock of Pacific would be held in escrow.
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Petitioner Charles H. Hansen entered into agreements on Nov. 23, 1962, to purchase all the stock of petitioner Pacific Coast Music Jobbers, Inc., whereby the sellers would receive $ 25,000 plus guaranteed dividends of a fixed amount over a 5-year period during which the stock of Pacific would be held in escrow. Held, Hansen became a shareholder of Pacific on Nov. 23, 1962, and his failure to consent to Pacific's election under sec. 1372 not to be subject to tax caused a termination of that election. Held, further, dividends distributed in 1964 to the sellers on account of the stock of Pacific…
1Opinion of the Court
Pacific Coast Music Jobbers, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Charles H. Hansen and Isabel Hansen, Petitioners v. Commissioner of Internal Revenue, Respondent
Pacific Coast Music Jobbers, Inc. v. Commissioner
Docket Nos. 284-68, 285-68
United States Tax Court
55 T.C. 866; 1971 U.S. Tax Ct. LEXIS 180;
February 25, 1971, Filed
Decisions will be entered for the respondent.
Petitioner Charles H. Hansen entered into agreements on Nov. 23, 1962, to purchase all the stock of petitioner Pacific Coast Music Jobbers, Inc., whereby the sellers would receive $ 25,000 plus…
2Cases cited20 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner of Internal Revenue v. Union Pac. R. Co.Court of Appeals for the Second Circuit · 1936
- Merrill v. CommissionerUnited States Tax Court · 1963
- Kean v. CommissionerUnited States Tax Court · 1968
- Monroe Zipp and Helen Zipp v. Commissioner of Internal Revenue, Bernard Zipp and Jean B. Zipp v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
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