T.J. Henry Associates, Inc. v. Commissioner
United States Tax Court
Held, bona fide transfer by the controlling shareholder in a subch. S corporation of one share of stock owned by him to himself as custodian under Uniform Gifts to Minors Act is recognized for tax purposes, and failure of new shareholder to consent to subch. S status terminates election.
1Opinion of the Court
T. J. Henry Associates, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Thomas J. Henry, Deceased, Arleen Costello (formerly Arleen Henry), Administratrix, and Arleen Costello (formerly Arleen Henry), Surviving Wife, Petitioners v. Commissioner of Internal Revenue, Respondent
T.J. Henry Associates, Inc. v. Commissioner
Docket Nos. 2826-81, 2827-81
United States Tax Court
80 T.C. 886; 1983 U.S. Tax Ct. LEXIS 81; 80 T.C. No. 47;
May 16, 1983, Filed
Decisions will be entered under Rule 155.
Held, bona fide transfer by the controlling shareholder in a subch. S corporation of…
2Cases cited12 opinions
- Hook v. CommissionerUnited States Tax Court · 1972
- William B. Wilson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977
- Goodman v. CommissionerUnited States Tax Court · 1980
- Joseph L. Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- Beirne v. CommissionerUnited States Tax Court · 1969
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