Hayden v. Commissioner
United States Tax Court
Held: 1. That the plan adopted by Spectacular Shows, Inc., on May 21, 1960, meets all the requirements of sec. 1244(c)(1)(A), I.R.C. 1954, and regulations thereto. 2. That the preincorporation subscriptions of petitioners were accepted on May 19, 1960, the date of incorporation, and the stock therefrom, accordingly, did not issue pursuant to the adopted plan of May 21, 1960. 3. The first 5,000 shares of stock paid for after the adoption of the plan, 5,000 shares being the…
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Held: 1. That the plan adopted by Spectacular Shows, Inc., on May 21, 1960, meets all the requirements of sec. 1244(c)(1)(A), I.R.C. 1954, and regulations thereto. 2. That the preincorporation subscriptions of petitioners were accepted on May 19, 1960, the date of incorporation, and the stock therefrom, accordingly, did not issue pursuant to the adopted plan of May 21, 1960. 3. The first 5,000 shares of stock paid for after the adoption of the plan, 5,000 shares being the maximum limit thereunder, were issued pursuant to such plan and qualify for ordinary-loss treatment under sec. 1244. 4.…
1Opinion of the Court
William O. Hayden and Wilda Joy Hayden, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Hayden v. Commissioner
Docket Nos. 6177-66, 6178-66, 6179-66, 6180-66
United States Tax Court
52 T.C. 1112; 1969 U.S. Tax Ct. LEXIS 50;
September 30, 1969, Filed
Decisions will be entered under Rule 50.
Held: 1. That the plan adopted by Spectacular Shows, Inc., on May 21, 1960, meets all the requirements of sec. 1244(c)(1)(A), I.R.C. 1954, and regulations thereto.
2. That the preincorporation subscriptions of petitioners were accepted on May 19, 1960, the date of incorporation, and the stock…
2Cases cited9 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Godart v. CommissionerUnited States Tax Court · 1969
- Spiegel v. CommissionerUnited States Tax Court · 1968
- Marsh v. CommissionerUnited States Tax Court · 1949
- Warner v. CommissionerUnited States Tax Court · 1967
4 more not listed; retrieve them via the Exa API.