Bialo v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Palmer v. CommissionerUnited States Tax Court · 1974
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
- Roebling v. CommissionerUnited States Tax Court · 1981
- Chamberlin v. CommissionerUnited States Tax Court · 1952
5 more not listed; retrieve them via the Exa API.