Duell v. Commissioner
United States Tax Court
During the taxable years 1954, 1955, and 1956, petitioner Charles H. Duell, without consideration, unconditionally surrendered for cancellation 2,120 shares of preferred stock in a corporation in which he was the principal common stockholder. There was no ratable contribution of their stock by the other stockholders to the corporation. Petitioner's purpose in surrendering the preferred stock was to improve the corporation's financial condition.
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During the taxable years 1954, 1955, and 1956, petitioner Charles H. Duell, without consideration, unconditionally surrendered for cancellation 2,120 shares of preferred stock in a corporation in which he was the principal common stockholder. There was no ratable contribution of their stock by the other stockholders to the corporation. Petitioner's purpose in surrendering the preferred stock was to improve the corporation's financial condition. The increase in value of petitioner's remaining stock in the corporation resulting from his surrender of the preferred stock was stipulated as $24.15…
1Opinion of the Court
Charles H. Duell and Ruth P. Duell v. Commissioner.
Duell v. Commissioner
Docket No. 78696.
United States Tax Court
T.C. Memo 1960-248; 1960 Tax Ct. Memo LEXIS 42; 19 T.C.M. (CCH) 1381; T.C.M. (RIA) 60248;
November 23, 1960
During the taxable years 1954, 1955, and 1956, petitioner Charles H. Duell, without consideration, unconditionally surrendered for cancellation 2,120 shares of preferred stock in a corporation in which he was the principal common stockholder. There was no ratable contribution of their stock by the other stockholders to the corporation. Petitioner's purpose in surrendering the…
2Cases cited7 opinions
- Budd International Corp. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1944
- Foster v. CommissionerUnited States Tax Court · 1947
- Budd International Corp. v. CommissionerUnited States Board of Tax Appeals · 1941
- Burdick v. CommissionerUnited States Board of Tax Appeals · 1930
- Haft v. CommissionerUnited States Board of Tax Appeals · 1930
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
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- Crow v. CommissionerUnited States Tax Court · 1970
- Leroy Frantz, Jr. And Sheila Frantz v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986