Victor E. Gidwitz Family Trust v. Commissioner
United States Tax Court
Petitioners received $ 225,000 in settlement of a lawsuit for defendants' failure to grant options pursuant to an oral agreement. The options were orally promised by the controlling shareholder of MSC to induce petitioners as shareholders of MSC to approve a merger of MSC and GD.
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Petitioners received $ 225,000 in settlement of a lawsuit for defendants' failure to grant options pursuant to an oral agreement. The options were orally promised by the controlling shareholder of MSC to induce petitioners as shareholders of MSC to approve a merger of MSC and GD. Held, the sum received in settlement represented consideration for MSC stock surrendered by petitioners in addition to GD stock received in the merger, taxable as gain realized from the sale or exchange of capital assets. Petitioners' GD preference shares were redeemed on Apr. 15, 1966. The redemption price expressly…
1Opinion of the Court
Victor E. Gidwitz Family Trust, Mercantile Bank and Trust Co., Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent; Michael Gidwitz II Trust, Mercantile Bank and Trust Co., Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent
Victor E. Gidwitz Family Trust v. Commissioner
Docket Nos. 4278-70, 4279-70
United States Tax Court
61 T.C. 664; 1974 U.S. Tax Ct. LEXIS 151; 61 T.C. No. 70;
February 21, 1974, Filed
Decisions will be entered under Rule 155.
Petitioners received $ 225,000 in settlement of a lawsuit for defendants' failure to grant options pursuant to an oral…
2Cases cited10 opinions
- United States v. GilmoreSupreme Court of the United States · 1963
- Woodward v. CommissionerSupreme Court of the United States · 1970
- United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Megargel v. CommissionerUnited States Tax Court · 1944
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