Legal Opinion

Kingsley v. Commissioner

United States Tax Court

Decided September 17, 1979No. Docket No. 9034-75Published

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

  1. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  2. Muzak Corp. v. Hotel Taft Corp.New York Court of Appeals · 1956
  3. In Re the Arbitration Between Western Union Telegraph Co. & American Communications Ass'nNew York Court of Appeals · 1949
  4. Farago v. BurkeNew York Court of Appeals · 1933
  5. Higgs v. De MaziroffNew York Court of Appeals · 1934

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