Legal Opinion

National Clothing Co. v. Commissioner

United States Tax Court

Decided February 28, 1955No. Docket Nos. 49334, 49397Published

Deductions -- Compensation -- Stock Sale and Repurchase Plan. -- The excess of the book value of stock paid by a corporation during the taxable years to repurchase the stock over the book value at the time the corporation transferred the stock to key employees pursuant to a contract which provided, inter alia, that the key employees purchase stock at book value and give in exchange non-interest-bearing demand notes with the stock as security, that the corporation apply all…

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Deductions -- Compensation -- Stock Sale and Repurchase Plan. -- The excess of the book value of stock paid by a corporation during the taxable years to repurchase the stock over the book value at the time the corporation transferred the stock to key employees pursuant to a contract which provided, inter alia, that the key employees purchase stock at book value and give in exchange non-interest-bearing demand notes with the stock as security, that the corporation apply all dividends on the notes until paid, and that the corporation have the right to repurchase the stock at book value upon the…

1Opinion of the Court

National Clothing Co. of Rochester, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent. Willard D. Avery, Petitioner, v. Commissioner of Internal Revenue, Respondent

National Clothing Co. v. Commissioner

Docket Nos. 49334, 49397

United States Tax Court

23 T.C. 944; 1955 U.S. Tax Ct. LEXIS 237;

February 28, 1955, Filed

Decisions will be entered under Rule 50.

Deductions -- Compensation -- Stock Sale and Repurchase Plan. -- The excess of the book value of stock paid by a corporation during the taxable years to repurchase the stock over the book value at the time the corporation…

2Cases cited1 opinion

  1. National Clothing Co. v. CommissionerUnited States Tax Court · 1955

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