Gray v. Commissioner
United States Tax Court
Yarg, a foreign personal holding company fully owned by petitioners in the years in issue, held preferred stock in Omark 1960, also a foreign corporation. Petitioners owned 90.4 percent of Omark 1960. Omark 1960 redeemed all of its preferred stock held by Yarg from Yarg on Sept. 25, 1962. That same day, petitioners sold all their stock in Yarg to independent third parties. Petitioners used the calendar year as their tax accounting period.
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Yarg, a foreign personal holding company fully owned by petitioners in the years in issue, held preferred stock in Omark 1960, also a foreign corporation. Petitioners owned 90.4 percent of Omark 1960. Omark 1960 redeemed all of its preferred stock held by Yarg from Yarg on Sept. 25, 1962. That same day, petitioners sold all their stock in Yarg to independent third parties. Petitioners used the calendar year as their tax accounting period. Omark 1960 and Yarg used a taxable year ending June 30. Held, on remand, petitioners are taxable in their taxable year 1963 on so much of Yarg's…
1Opinion of the Court
John D. Gray and Elizabeth N. Gray, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Gray v. Commissioner
Docket Nos. 2376-68, 2377-68, 2378-68, 2379-68, 2380-68, 2381-68
United States Tax Court
71 T.C. 719; 1979 U.S. Tax Ct. LEXIS 180;
February 1, 1979, Filed
Decisions will be entered under Rule 155.
Yarg, a foreign personal holding company fully owned by petitioners in the years in issue, held preferred stock in Omark 1960, also a foreign corporation. Petitioners owned 90.4 percent of Omark 1960. Omark 1960 redeemed all of its preferred stock held by Yarg from Yarg on Sept.…
2Cases cited2 opinions
- Gray v. CommissionerCourt of Appeals for the Ninth Circuit · 1977
- Gray v. CommissionerUnited States Tax Court · 1979