W. T. Grant Co. v. Commissioner
United States Tax Court
The petitioner maintains a coupon book installment plan under which a book of coupons is paid for in installments, and the coupons may be exchanged for merchandise at any of the petitioner's stores. During 1964 and 1965, the petitioner also maintained plans under which certain employees were given the opportunity to purchase shares of the petitioner's stock and to pay for it over a 10-year period. Such stock was not to be issued until it was fully paid for.
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The petitioner maintains a coupon book installment plan under which a book of coupons is paid for in installments, and the coupons may be exchanged for merchandise at any of the petitioner's stores. During 1964 and 1965, the petitioner also maintained plans under which certain employees were given the opportunity to purchase shares of the petitioner's stock and to pay for it over a 10-year period. Such stock was not to be issued until it was fully paid for. Before the stock was issued, the petitioner quarterly credited each participating employee's purchase account with certain net dividend…
1Opinion of the Court
W. T. Grant Company, Petitioner v. Commissioner of Internal Revenue, Respondent
W. T. Grant Co. v. Commissioner
Docket No. 1813-68
United States Tax Court
58 T.C. 290; 1972 U.S. Tax Ct. LEXIS 122;
May 15, 1972, Filed
Decision will be entered under Rule 50.
The petitioner maintains a coupon book installment plan under which a book of coupons is paid for in installments, and the coupons may be exchanged for merchandise at any of the petitioner's stores. During 1964 and 1965, the petitioner also maintained plans under which certain employees were given the opportunity to purchase shares of the…
Also in this document: Dissent.
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Burnet v. S. & L. Building Corp.Supreme Court of the United States · 1933
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Prendergast v. CommissionerUnited States Board of Tax Appeals · 1931
- Blum's, Inc. v. CommissionerUnited States Board of Tax Appeals · 1927
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