Legal Opinion

Estate of Schott v. Commissioner

United States Tax Court

Decided April 26, 1982No. Docket No. 5283-78Unpublished

The top management employees of the Evendale operations of Avco sought to purchase that operation. The primary source of income of Evendale was from the manufacture and sale of high technology components to the U.S. Government. In order to effect the purchase, the employees organized CEC. The purchase could not be consummated without providing performance bonds covering the government contracts.

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The top management employees of the Evendale operations of Avco sought to purchase that operation. The primary source of income of Evendale was from the manufacture and sale of high technology components to the U.S. Government. In order to effect the purchase, the employees organized CEC. The purchase could not be consummated without providing performance bonds covering the government contracts. After extensive negotiations, Harold Schott, an unrelated party, agreed to provide collateral for the performance bonds, to purchase and lease back the land and buildings of Evendale, to acquire a…

1Opinion of the Court

ESTATE OF HAROLD C. SCHOTT, DECEASED, HOWARD J. VANDEN EYNDEN AND L. THOMAS HILTZ, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Schott v. Commissioner

Docket No. 5283-78.

United States Tax Court

T.C. Memo 1982-222; 1982 Tax Ct. Memo LEXIS 528; 43 T.C.M. (CCH) 1188; T.C.M. (RIA) 82222;

April 26, 1982.

The top management employees of the Evendale operations of Avco sought to purchase that operation. The primary source of income of Evendale was from the manufacture and sale of high technology components to the U.S. Government. In order to effect the purchase, the…

2Cases cited10 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. PhellisSupreme Court of the United States · 1921
  3. Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
  4. VGS Corp. v. CommissionerUnited States Tax Court · 1977
  5. Duncan Industries, Inc., etc. v. CommissionerUnited States Tax Court · 1979

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