Legal Opinion

Bowen v. Commissioner

United States Tax Court

Decided January 20, 1982No. Docket No. 12745-79Published

Husband and wife each owned stock in a publicly held corporation. Their combined ownership enabled the husband to retain control over the corporation despite an approximate 35-percent stock ownership by the wife's brother. In 1973, the wife sold her stock to her husband on the installment basis. The installment payments were to be made over a period of 40 years with a "balloon" payment due at the end of that period.

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Husband and wife each owned stock in a publicly held corporation. Their combined ownership enabled the husband to retain control over the corporation despite an approximate 35-percent stock ownership by the wife's brother. In 1973, the wife sold her stock to her husband on the installment basis. The installment payments were to be made over a period of 40 years with a "balloon" payment due at the end of that period. Subsequently, in late 1974, the husband sold to a Canadian corporation a portion of the shares purchased from his wife. This sale also was on the installment basis. In computing…

1Opinion of the Court

Robert R. Bowen and Elizabeth S. Bowen, Petitioners v. Commissioner of Internal Revenue, Respondent

Bowen v. Commissioner

Docket No. 12745-79

United States Tax Court

78 T.C. 55; 1982 U.S. Tax Ct. LEXIS 148; 78 T.C. No. 5;

January 20, 1982, Filed

Decision will be entered for the petitioners.

Husband and wife each owned stock in a publicly held corporation. Their combined ownership enabled the husband to retain control over the corporation despite an approximate 35-percent stock ownership by the wife's brother. In 1973, the wife sold her stock to her husband on the installment basis. The installment…

2Cases cited25 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Corliss v. BowersSupreme Court of the United States · 1930
  3. United States v. PhellisSupreme Court of the United States · 1921
  4. Griffiths v. CommissionerSupreme Court of the United States · 1939
  5. Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981

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