Legal Opinion
Michael Ferguson and Valene Ferguson v. Commissioner
United States Tax Court
Decided April 28, 1997No. 21808-93, 18250-94Unknown
1Opinion of the Court
108 T.C. No. 14
UNITED STATES TAX COURT MICHAEL FERGUSON AND VALENE FERGUSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent ROGER N. FERGUSON AND SYBIL FERGUSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 21808-93, 18250-94. Filed April 28, 1997. Held: Ps donated to various charitable organizations (the Charities) appreciated stock in C1. Prior to the gifts, C1 and C2 entered into a merger agreement, C2 made a tender offer for the shares of C1, and shares of C1 sufficient to approve the merger were tendered or guaranteed. The Charities subsequently…
2Cases cited19 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Leonard Greene and Joyce Greene v. United StatesCourt of Appeals for the Second Circuit · 1994
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
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