Frahm v. Commissioner
United States Tax Court
Petitioner organized a corporation, the minutes of which authorized the issuance of stock pursuant to a permit granted by the California Commissioner of Corporations. The permit as granted terminated within one year, but could be revoked, suspended, or renewed at anytime.
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Petitioner organized a corporation, the minutes of which authorized the issuance of stock pursuant to a permit granted by the California Commissioner of Corporations. The permit as granted terminated within one year, but could be revoked, suspended, or renewed at anytime. Held: The minutes of the corporation together with the permit did not constitute a "plan" within the meaning of section 1244(c) (1) (A), and therefore petitioner must recognize a capital loss on the sale of his stock in the corporation. John H. Rickey, 54 T.C. 680 (1970), on appeal (C.A. 9, Nov. 13, 1970) followed. Held…
1Opinion of the Court
GEORGE H. FRAHM and ELIZABETH A. FRAHM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Frahm v. Commissioner
Docket No. 668-71
United States Tax Court
T.C. Memo 1974-138; 1974 Tax Ct. Memo LEXIS 181; 33 T.C.M. (CCH) 622; T.C.M. (RIA) 74138;
May 30, 1974, Filed.
Petitioner organized a corporation, the minutes of which authorized the issuance of stock pursuant to a permit granted by the California Commissioner of Corporations. The permit as granted terminated within one year, but could be revoked, suspended, or renewed at anytime. Held: The minutes of the corporation together with the…
2Cases cited11 opinions
- Heiner v. TindleSupreme Court of the United States · 1928
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Godart v. CommissionerUnited States Tax Court · 1969
- Mance T. Spillers and Mary J. Spillers v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Warner v. CommissionerUnited States Tax Court · 1967
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