Richard E. and Mary Ann Hurst v. Commissioner

124 T.C. No. 2

UNITED STATES TAX COURT RICHARD E. AND MARY ANN HURST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15792-02. Filed February 3, 2005. In 1997, as part of their retirement planning, Ps sold their stock in R Corp. to H Corp. H Corp. redeemed 90 percent of P-husband’s stock in H Corp., and P-husband sold the remainder to his son and two third parties. Both the redemption and stock sales provided for payment over 15 years and were secured by the shares of stock being redeemed or sold. Ps continued to own H Corp.’s headquarters building, which they leased…