Glacier State Electric Supply Co. v. Commissioner
United States Tax Court
P is a corporation organized in 1946. P's shares were issued in effect one-half each to X and Y. Z, X, and Y organized a second corporation (GSB) in 1953. The stock of GSB was issued one-third to Z and two-thirds to P. These parties executed buy/sell agreements. After amendments in 1969, the agreements provided that one-half of the GSB shares held by P would be redeemed upon the death of X or Y and that all of Z's shares would be redeemed upon Z's death.
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P is a corporation organized in 1946. P's shares were issued in effect one-half each to X and Y. Z, X, and Y organized a second corporation (GSB) in 1953. The stock of GSB was issued one-third to Z and two-thirds to P. These parties executed buy/sell agreements. After amendments in 1969, the agreements provided that one-half of the GSB shares held by P would be redeemed upon the death of X or Y and that all of Z's shares would be redeemed upon Z's death. X died in 1976. Pursuant to the buy/sell agreements, two redemptions occurred. P received a check plus a 5-year note in return for one-half…
1Opinion of the Court
Dawson, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes for the years 1976 and 1977 in the amounts of $7,350.71 and $38,943.17, respectively. Concessions have been made by the parties. The issues remaining for decision are:(1) Whether the step transaction doctrine should be applied to treat a contemporaneous redemption of a portion of the stock of petitioner’s subsidiary and a redemption of some of its own stock as a distribution of the subsidiary stock to the estate of a deceased shareholder of petitioner, followed by a redemption of that distributed stock…
2Cases cited26 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- United States v. DavisSupreme Court of the United States · 1970
- Foster v. Comm'rUnited States Tax Court · 1983
21 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Estate of Durkin v. CommissionerUnited States Tax Court · 1992
- Slawek v. CommissionerUnited States Tax Court · 1987
- Wentz v. CommissionerUnited States Tax Court · 1995
- Schneiderman v. CommissionerUnited States Tax Court · 1987
- Pabst Brewing Co. v. CommissionerUnited States Tax Court · 1995
12 more not listed; retrieve them via the Exa API.