Paparo v. Commissioner
United States Tax Court
Petitioners sought to treat amounts distributed in redemption of their stock in related corporations as distributions in full payment in exchange for their stock under sec. 302(a), I.R.C. 1954. Held, the redemption of such stock from petitioners was "essentially equivalent to a dividend" within the provisions of sec. 302(b)(1) and was properly treated as distributions of property to which sec. 301 applied. United States v. Davis, 397 U.S. 301 (1970).
1Opinion of the Court
Forrester, Judge:
In these consolidated cases, respondent has determined the following deficiencies:
Docket Taxable
No. Petitioner year Deficiency
4580-74 Jack Paparo, individually and as surviving spouse of Katherine Paparo, deceased . 1970 $27,001.84
1971 25,217.12
4581-74 Irving Paparo and Renee 1970 36,615.68 Paparo . 1971 17,764.00
The sole issue for our decision is whether the amounts which Jack Paparo and Irving Paparo received in 1970 and 1971 from House of Ronnie, Inc., in exchange for their stock in Nashville Textile Corp. and Jasper Textile Corp., are taxable as capital gains under…
2Cases cited13 opinions
- United States v. DavisSupreme Court of the United States · 1970
- Commissioner v. GordonSupreme Court of the United States · 1968
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Haft Trust v. CommissionerUnited States Tax Court · 1974
8 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Merrill Lynch & Co., Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2004
- Glacier State Electric Supply Co. v. CommissionerUnited States Tax Court · 1983
- Roebling v. CommissionerUnited States Tax Court · 1981
- Merrill Lynch & Co. v. Comm'rUnited States Tax Court · 2003
- Johnston v. CommissionerUnited States Tax Court · 1981
9 more not listed; retrieve them via the Exa API.