McLain v. Commissioner
United States Tax Court
Rule 121, Tax Court Rules of Practice and Procedure. -- For purposes only of their motion for summary judgment, petitioners concede that certain shares of stock standing in the name of their attorney were, in fact, beneficially owned by them. The beneficial ownership of such shares remains for adjudication, however, in a related case, the outcome of which will be predicated upon such ownership.
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Rule 121, Tax Court Rules of Practice and Procedure. -- For purposes only of their motion for summary judgment, petitioners concede that certain shares of stock standing in the name of their attorney were, in fact, beneficially owned by them. The beneficial ownership of such shares remains for adjudication, however, in a related case, the outcome of which will be predicated upon such ownership. The issue in the related case, Bunte Candies, Inc., docket No. 4882-76, arose out of the same series of transactions involved in the instant case and, although no motion for consolidation for trial has…
1Opinion of the Court
Robert T. McLain and Janet W. McLain, Petitioners v. Commissioner of Internal Revenue, Respondent
McLain v. Commissioner
Docket No. 4891-76
United States Tax Court
67 T.C. 775; 1977 U.S. Tax Ct. LEXIS 158;
February 3, 1977, Filed
Rule 121, Tax Court Rules of Practice and Procedure. -- For purposes only of their motion for summary judgment, petitioners concede that certain shares of stock standing in the name of their attorney were, in fact, beneficially owned by them. The beneficial ownership of such shares remains for adjudication, however, in a related case, the outcome of which will be…
2Cases cited10 opinions
- Begnaud v. WhiteCourt of Appeals for the Sixth Circuit · 1948
- American Fidelity and Casualty Company, Inc. v. The London and Edinburgh Insurance Company, Limited, and the Dominion Insurance Company, LimitedCourt of Appeals for the Fourth Circuit · 1965
- Hoeme v. CommissionerUnited States Tax Court · 1974
- Broderick Wood Products Co. v. United StatesCourt of Appeals for the Tenth Circuit · 1952
- Nafco Oil and Gas, Inc., a Corporation v. Nathan ApplemanCourt of Appeals for the Tenth Circuit · 1967
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