Leib v. Commissioner
United States Tax Court
Petitioner, a dentist, conducted his private practice through a wholly owned professional corporation. The professional corporation established an employees pension trust, with petitioner as trustee. In December 1980, petitioner sold stock to the trust for cash and a non-interest-bearing demand note. In February 1981, the trust sold the stock to a third party and paid off the note.
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Petitioner, a dentist, conducted his private practice through a wholly owned professional corporation. The professional corporation established an employees pension trust, with petitioner as trustee. In December 1980, petitioner sold stock to the trust for cash and a non-interest-bearing demand note. In February 1981, the trust sold the stock to a third party and paid off the note. In December 1981, petitioner determined that the price at which he sold the stock to the trust exceeded the price that the trust would have had to pay for the stock on the open market, and paid such difference to…
1Opinion of the Court
Alden M. Leib, Petitioner v. Commissioner of Internal Revenue, Respondent
Leib v. Commissioner
Docket No. 10688-85
United States Tax Court
88 T.C. 1474; 1987 U.S. Tax Ct. LEXIS 84; 88 T.C. No. 83; 9 Employee Benefits Cas. (BNA) 1017;
June 16, 1987. June 16, 1987, Filed
Decision will be entered for the respondent.
Petitioner, a dentist, conducted his private practice through a wholly owned professional corporation. The professional corporation established an employees pension trust, with petitioner as trustee. In December 1980, petitioner sold stock to the trust for cash and a non-interest-bearing…
2Cases cited14 opinions
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- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Donovan v. CunninghamCourt of Appeals for the Fifth Circuit · 1983
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
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