Crowe v. Commissioner
United States Tax Court
As a condition to his purchase of one-half the stock of Rayburn Land Co., the petitioner was required by the other shareholder to grant that shareholder a unilateral option for 5 years whereby the latter shareholder could reacquire the petitioner's 50-percent stock interest.
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As a condition to his purchase of one-half the stock of Rayburn Land Co., the petitioner was required by the other shareholder to grant that shareholder a unilateral option for 5 years whereby the latter shareholder could reacquire the petitioner's 50-percent stock interest. Prior to the completion of construction and following disagreements over development policy, the latter shareholder exercised the option, purchased the petitioner's stock, and continued to operate the corporation. Held, Rayburn Land Co. was not a collapsible corporation within the meaning of sec. 341 since the view…
1Opinion of the Court
Joseph M. Crowe and Kathryn K. Crowe, Petitioners v. Commissioner of Internal Revenue, Respondent
Crowe v. Commissioner
Docket No. 2436-72
United States Tax Court
62 T.C. 121; 1974 U.S. Tax Ct. LEXIS 119; 62 T.C. No. 14;
April 30, 1974, Filed
Decision will be entered for the petitioners.
As a condition to his purchase of one-half the stock of Rayburn Land Co., the petitioner was required by the other shareholder to grant that shareholder a unilateral option for 5 years whereby the latter shareholder could reacquire the petitioner's 50-percent stock interest. Prior to the completion of construction…
2Cases cited10 opinions
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- Farber v. CommissionerUnited States Tax Court · 1961
- Jack and Celia Farber v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Rechner v. CommissionerUnited States Tax Court · 1958
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