Peterson v. Commissioner
United States Tax Court
The stock of X corporation was held 37 1/2 percent by a trust, 37 1/2 percent by M, the vice-president and manager, and 25 percent by R, the president.
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The stock of X corporation was held 37 1/2 percent by a trust, 37 1/2 percent by M, the vice-president and manager, and 25 percent by R, the president. Under unusual circumstances, M offered in 1958 to sell all of his shares, under an option agreement which he prepared, to R. Upon the whole record it is held: That R acted for a syndicate consisting of the trust, individuals, himself, and the corporation who were the actual purchasers of the 375 shares of M; that the corporation acquired it from M, not R (the petitioner), and redeemed 128 shares, under section 317(b), 1954 Code, for $192,000;…
1Opinion of the Court
Robert N. Peterson and Martha T. Peterson v. Commissioner.
Peterson v. Commissioner
Docket No. 95108.
United States Tax Court
T.C. Memo 1964-15; 1964 Tax Ct. Memo LEXIS 322; 23 T.C.M. (CCH) 63; T.C.M. (RIA) 64015;
January 28, 1964
The stock of X corporation was held 37 1/2 percent by a trust, 37 1/2 percent by M, the vice-president and manager, and 25 percent by R, the president. Under unusual circumstances, M offered in 1958 to sell all of his shares, under an option agreement which he prepared, to R. Upon the whole record it is held: That R acted for a syndicate consisting of the trust,…
2Cases cited16 opinions
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Joseph R. Holsey and Eleanor T. Holsey v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Decker v. CommissionerUnited States Tax Court · 1959
- Fox v. HarrisonCourt of Appeals for the Seventh Circuit · 1944
11 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Bennett v. CommissionerUnited States Tax Court · 1972
- Schroeder v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- David L. Schroeder and Tana Schroeder v. Commissioner of Internal Revenue Service, Skyline Memorial Gardens, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- Bennett v. CommissionerUnited States Tax Court · 1972