De Vito v. Commissioner
United States Tax Court
P and other parties were sued for breach of employment contract and breach of fiduciary duties. In settlement of such action, P and his co-defendants agreed to transfer 30,000 shares of C stock.
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P and other parties were sued for breach of employment contract and breach of fiduciary duties. In settlement of such action, P and his co-defendants agreed to transfer 30,000 shares of C stock. To acquire such stock, P and his co-defendants entered into separate contracts for the purchase of such stock from a third party, W. The number of shares to be purchased and transferred in settlement was allocated among P and his co-defendants pursuant to a separate agreement to which W was not a party. According to such agreement, P was to purchase and transfer 5,000 shares. Subsequent to the date…
1Opinion of the Court
ALBERT P. DeVITO and MARGARET DeVITO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
De Vito v. Commissioner
Docket No. 7216-77.
United States Tax Court
T.C. Memo 1979-377; 1979 Tax Ct. Memo LEXIS 145; 39 T.C.M. (CCH) 152; T.C.M. (RIA) 79377;
September 17, 1979, Filed
P and other parties were sued for breach of employment contract and breach of fiduciary duties. In settlement of such action, P and his co-defendants agreed to transfer 30,000 shares of C stock. To acquire such stock, P and his co-defendants entered into separate contracts for the purchase of such stock from a third…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Bixby v. CommissionerUnited States Tax Court · 1972
- United States v. GilmoreSupreme Court of the United States · 1963
- United States v. CartwrightSupreme Court of the United States · 1973
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