Legal Opinion

Hightower v. Comm'r

United States Tax Court

Decided November 28, 2005No. 8679-04UnpublishedCited by 1 opinion

Petitioner (P) and Daniel O'Dowd each owned 50 percent of the stock of an S corporation (GH). O'Dowd exercised his rights under the shareholders' agreement to buy P's shares. P opposed the buyout in arbitration proceedings to which P and O'Dowd had agreed to be bound. In 2000, the arbitrator ruled against P, and P received $ 41,585,388 in exchange for his GH stock. P deposited the payment in an interest-bearing account.

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Petitioner (P) and Daniel O'Dowd each owned 50 percent of the stock of an S corporation (GH). O'Dowd exercised his rights under the shareholders' agreement to buy P's shares. P opposed the buyout in arbitration proceedings to which P and O'Dowd had agreed to be bound. In 2000, the arbitrator ruled against P, and P received $ 41,585,388 in exchange for his GH stock. P deposited the payment in an interest-bearing account. From 2000 to 2003, P unsuccessfully opposed the buyout in California State courts. P received no dividends from GH in 2000, but he retained the right to receive dividends and…

1Opinion of the Court

GLENN HIGHTOWER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hightower v. Comm'r

No. 8679-04

United States Tax Court

T.C. Memo 2005-274; 2005 Tax Ct. Memo LEXIS 264; 90 T.C.M. (CCH) 530;

November 28, 2005, Filed

The court found in favor of the Commissioner.

Petitioner (P) and Daniel O'Dowd each owned 50 percent of the

stock of an S corporation (GH). O'Dowd exercised his rights

under the shareholders' agreement to buy P's shares. P opposed

the buyout in arbitration proceedings to which P and O'Dowd had

agreed to be bound. In 2000, the arbitrator ruled against P, and

P received $ 41,585,388…

2Cases cited29 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  3. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  4. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  5. Healy v. CommissionerSupreme Court of the United States · 1953

24 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Clinton Deckard v. CommissionerUnited States Tax Court · 2020

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