De Groff v. Commissioner
United States Tax Court
Midwest Applied Science Corporation (MASC) offered stock pursuant to a plan adopted in 1967. The plan made no reference to sec. 1244, I.R.C. 1954, or the benefits thereunder. Further, the plan failed to limit the period during which the stock could be offered. In 1972, MASC stock purchased by petitioners pursuant to the 1967 plan became worthless. Held, petitioners are not entitled to treat their loss on the MASC stock as an ordinary loss.
1Opinion of the Court
HAROLD M. DeGROFF, JR., and SARAH M. DeGROFF, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
De Groff v. Commissioner
Docket No. 2306-76.
United States Tax Court
T.C. Memo 1977-318; 1977 Tax Ct. Memo LEXIS 126; 36 T.C.M. (CCH) 1284; T.C.M. (RIA) 770318;
Filed September 19, 1977.
Midwest Applied Science Corporation (MASC) offered stock pursuant to a plan adopted in 1967. The plan made no reference to sec. 1244, I.R.C. 1954, or the benefits thereunder. Further, the plan failed to limit the period during which the stock could be offered. In 1972, MASC stock purchased by petitioners…
2Cases cited7 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Godart v. CommissionerUnited States Tax Court · 1969
- Hayden v. CommissionerUnited States Tax Court · 1969
- John H. Rickey and Lorraine C. Rickey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
2 more not listed; retrieve them via the Exa API.