Legal Opinion
DTDV, LLC, Richard G. Vento, Tax Matters Partner v. Commissioner
United States Tax Court
Decided March 20, 2018No. 741-09UnpublishedCited by 1 opinion
1Opinion of the Court
T.C. Memo. 2018-32
UNITED STATES TAX COURT DTDV, LLC, RICHARD G. VENTO, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 741-09. Filed March 20, 2018. P transferred stock in O Corp. to D, a limited liability company, when O was negotiating its possible acquisition by A Corp. On Nov. 24, 2000, O and A executed agreements providing for A's acquisition of O's stock for $17.75 per share. On that same day, P assigned a 36% interest in D to S, a foreign entity formed to hold segregated account investment reserves in support of an insurance policy on P's…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Weiner v. United StatesCourt of Appeals for the Fifth Circuit · 2004
- Compaq Computer Corporation & Subsidiaries v. CommissionerCourt of Appeals for the Fifth Circuit · 2001
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3Cited by1 opinion
- Renee Vento v. CommissionerUnited States Tax Court · 2019