Kingsley v. Commissioner
United States Tax Court
Petitioner entered into a stock-for-stock tax-free reorganization agreement with A in 1966. Most of the shares of A's common stock petitioner was to receive were delivered to him at closing. The balance was reserved to meet contingent claims and delivered to petitioner in April 1970, 3 years and 5 months later. The number of shares of stock delivered in 1970 was adjusted to reflect both a stock split and interim dividends that would have been paid on the reserved shares.
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Petitioner entered into a stock-for-stock tax-free reorganization agreement with A in 1966. Most of the shares of A's common stock petitioner was to receive were delivered to him at closing. The balance was reserved to meet contingent claims and delivered to petitioner in April 1970, 3 years and 5 months later. The number of shares of stock delivered in 1970 was adjusted to reflect both a stock split and interim dividends that would have been paid on the reserved shares. The time of the later delivery was indefinite under the agreement, being the latter of 3 years after closing or the final…
1Opinion of the Court
Jerrold L. Kingsley and June H. Kingsley, Petitioners v. Commissioner of Internal Revenue, Respondent
Kingsley v. Commissioner
Docket No. 9034-75
United States Tax Court
72 T.C. 1095; 1979 U.S. Tax Ct. LEXIS 57;
September 17, 1979, Filed
Decision will be entered for the respondent.
Petitioner entered into a stock-for-stock tax-free reorganization agreement with A in 1966. Most of the shares of A's common stock petitioner was to receive were delivered to him at closing. The balance was reserved to meet contingent claims and delivered to petitioner in April 1970, 3 years and 5 months later. The number…
2Cases cited17 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Muzak Corp. v. Hotel Taft Corp.New York Court of Appeals · 1956
- In Re the Arbitration Between Western Union Telegraph Co. & American Communications Ass'nNew York Court of Appeals · 1949
- Farago v. BurkeNew York Court of Appeals · 1933
- Higgs v. De MaziroffNew York Court of Appeals · 1934
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