Legal Opinion

Bialo v. Commissioner

United States Tax Court

Decided April 30, 1987No. Docket No. 17358-83Published

Petitioners' closely held corporation issued a pro rata dividend of preferred stock on common stock which petitioners contributed to a charitable trust. The stock was then redeemed by the corporation. Held, one of the principal purposes of the distribution and redemption was the avoidance of Federal income tax and the amount of petitioners' deduction is subject to the limitations contained in sec. 170(e)(1)(A), I.R.C. 1954.

1Opinion of the Court

Walter Bialo and Mildred Bialo, Petitioners v. Commissioner of Internal Revenue, Respondent

Bialo v. Commissioner

Docket No. 17358-83

United States Tax Court

88 T.C. 1132; 1987 U.S. Tax Ct. LEXIS 63; 88 T.C. No. 63;

April 30, 1987. April 30, 1987, Filed

Decision will be entered under Rule 155.

Petitioners' closely held corporation issued a pro rata dividend of preferred stock on common stock which petitioners contributed to a charitable trust. The stock was then redeemed by the corporation. Held, one of the principal purposes of the distribution and redemption was the avoidance of Federal income tax…

2Cases cited10 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Palmer v. CommissionerUnited States Tax Court · 1974
  3. Humacid Co. v. CommissionerUnited States Tax Court · 1964
  4. Roebling v. CommissionerUnited States Tax Court · 1981
  5. Chamberlin v. CommissionerUnited States Tax Court · 1952

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