Fisher v. Commissioner
United States Tax Court
Petitioner agreed to exchange all the stock of F corporation for 168,800 shares of voting preferred stock in A corporation. On the shares received by the petitioner, dividends were to accrue after Dec. 15, 1966, regardless of the actual date of closing.
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Petitioner agreed to exchange all the stock of F corporation for 168,800 shares of voting preferred stock in A corporation. On the shares received by the petitioner, dividends were to accrue after Dec. 15, 1966, regardless of the actual date of closing. However, because the petitioner's counsel was concerned over the possibility that the receipt of a cash dividend might cause the IRS to rule that the exchange would not qualify as a "B reorganization," the agreement was modified to provide that in the event the closing did not take place until after Dec. 15, 1966, no cash dividends would…
1Opinion of the Court
J. Robert Fisher, Petitioner v. Commissioner of Internal Revenue, Respondent
Fisher v. Commissioner
Docket No. 4885-71
United States Tax Court
62 T.C. 73; 1974 U.S. Tax Ct. LEXIS 122; 62 T.C. No. 9;
April 22, 1974, Filed
Decision will be entered under Rule 155.
Petitioner agreed to exchange all the stock of F corporation for 168,800 shares of voting preferred stock in A corporation. On the shares received by the petitioner, dividends were to accrue after Dec. 15, 1966, regardless of the actual date of closing. However, because the petitioner's counsel was concerned over the possibility that the…
2Cases cited37 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. EubankSupreme Court of the United States · 1941
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