Niedermeyer v. Commissioner
United States Tax Court
Petitioners, husband and wife, owned 22.58 percent of the common stock of AT&T and 125 shares of its preferred stock. Two of petitioners' sons owned 67.91 percent of the common stock of AT&T. Petitioners owned no stock of Lents but three of their other sons owned 67 percent of its common stock. On Sept. 8, 1966, petitioners sold their AT&T common stock to Lents, and on Dec. 28, 1966, petitioners contributed their AT&T preferred stock to the Niedermeyer Foundation.
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Petitioners, husband and wife, owned 22.58 percent of the common stock of AT&T and 125 shares of its preferred stock. Two of petitioners' sons owned 67.91 percent of the common stock of AT&T. Petitioners owned no stock of Lents but three of their other sons owned 67 percent of its common stock. On Sept. 8, 1966, petitioners sold their AT&T common stock to Lents, and on Dec. 28, 1966, petitioners contributed their AT&T preferred stock to the Niedermeyer Foundation. Held, (1) the sale of the AT&T common stock constituted a redemption through the use of a related corporation under sec.…
1Opinion of the Court
Bernard E. Niedermeyer and Tessie S. Niedermeyer, Petitioners v. Commissioner of Internal Revenue, Respondent
Niedermeyer v. Commissioner
Docket No. 1673-71
United States Tax Court
62 T.C. 280; 1974 U.S. Tax Ct. LEXIS 98; 62 T.C. No. 34;
June 6, 1974, Filed
Decision will be entered for the respondent.
Petitioners, husband and wife, owned 22.58 percent of the common stock of AT&T and 125 shares of its preferred stock. Two of petitioners' sons owned 67.91 percent of the common stock of AT&T. Petitioners owned no stock of Lents but three of their other sons owned 67 percent of its common stock. On…
2Cases cited24 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- United States v. DavisSupreme Court of the United States · 1970
- O. H. Kruse Grain & Milling v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Cary v. CommissionerUnited States Tax Court · 1963
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