Pope v. Commissioner
United States Tax Court
Petitioner in 1949 sold some of his shares of stock in a corporation controlled by him to another corporation also controlled by him. Held: the sale did not lack economic reality and all the proceeds did not constitute a dividend to petitioner. John Wanamaker (Phila.) Trustees Common Stock, 11 T.C. 365, affd. 178 Fed. (2d) 10; and Emma Cramer, 20 T.C. 679, followed.
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Petitioner in 1949 sold some of his shares of stock in a corporation controlled by him to another corporation also controlled by him. Held: the sale did not lack economic reality and all the proceeds did not constitute a dividend to petitioner. John Wanamaker (Phila.) Trustees Common Stock, 11 T.C. 365, affd. 178 Fed. (2d) 10; and Emma Cramer, 20 T.C. 679, followed. Held further: in the absence of evidence to the contrary by respondent, evidence as to the book values of the issuing corporation's assets and its earning power accepted as establishing the fair market value of the corporation's…
1Opinion of the Court
Roger W. Pope and Marjorie H. Pope v. Commissioner.
Pope v. Commissioner
Docket No. 53344.
United States Tax Court
T.C. Memo 1956-41; 1956 Tax Ct. Memo LEXIS 255; 15 T.C.M. (CCH) 181; T.C.M. (RIA) 56041;
February 23, 1956
Petitioner in 1949 sold some of his shares of stock in a corporation controlled by him to another corporation also controlled by him. Held: the sale did not lack economic reality and all the proceeds did not constitute a dividend to petitioner. John Wanamaker (Phila.) Trustees Common Stock, 11 T.C. 365, affd. 178 Fed. (2d) 10; and Emma Cramer, 20 T.C. 679, followed. Held further:…
2Cases cited6 opinions
- Kaplan v. CommissionerUnited States Tax Court · 1953
- Edwards v. CommissionerUnited States Board of Tax Appeals · 1939
- Perkins v. CommissionerUnited States Board of Tax Appeals · 1940
- Evans v. CommissionerUnited States Board of Tax Appeals · 1934
- May v. CommissionerUnited States Board of Tax Appeals · 1936
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