Legal Opinion

Edwards v. Commissioner

United States Tax Court

Decided August 9, 1989No. Docket No. 34900-87UnpublishedCited by 5 opinions

Petitioner was an employee of HPNA, a professional corporation, from 1974 through 1984. On June 1, 1982, one of HPNA's two physician-shareholders purchased all of the stock owned by the other shareholder. The selling shareholder and another physician organized Piedmont, a separate professional corporation providing similar services.

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Petitioner was an employee of HPNA, a professional corporation, from 1974 through 1984. On June 1, 1982, one of HPNA's two physician-shareholders purchased all of the stock owned by the other shareholder. The selling shareholder and another physician organized Piedmont, a separate professional corporation providing similar services. For approximately 1 year after Piedmont was organized, petitioner was employed by both Piedmont and HPNA, and performed services for each on approximately a half-time basis. Sometime prior to June 1, 1983, petitioner terminated her employment with Piedmont and…

1Opinion of the Court

ROY G. EDWARDS AND DEBORAH S. EDWARDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Edwards v. Commissioner

Docket No. 34900-87

United States Tax Court

T.C. Memo 1989-409; 1989 Tax Ct. Memo LEXIS 407; 57 T.C.M. (CCH) 1217; T.C.M. (RIA) 89409; 11 Employee Benefits Cas. (BNA) 1406;

August 9, 1989

Petitioner was an employee of HPNA, a professional corporation, from 1974 through 1984. On June 1, 1982, one of HPNA's two physician-shareholders purchased all of the stock owned by the other shareholder. The selling shareholder and another physician organized Piedmont, a separate professional…

2Cases cited10 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Miller v. CommissionerUnited States Tax Court · 1954
  3. Glinske v. CommissionerUnited States Tax Court · 1951
  4. United States v. Ben Martin and Rachel T. MartinCourt of Appeals for the Eighth Circuit · 1964
  5. Gittens v. CommissionerUnited States Tax Court · 1968

5 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Burton v. CommissionerUnited States Tax Court · 1992
  2. Cross v. Elected Officials Retirement PlanCourt of Appeals of Arizona · 2014
  3. Baskovich v. CommissionerUnited States Tax Court · 1991
  4. Burton v. CommissionerUnited States Tax Court · 1992
  5. Vidrine v. CommissionerUnited States Tax Court · 1993

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