Legal Opinion

Weisbart v. Commissioner

United States Tax Court

Decided September 23, 1982No. Docket No. 8926-80Published

Petitioner owned 45 percent of S and 100 percent of W. Gary, petitioner's nephew, controlled 7AL and GW. W and GW each owned 50 percent of W & W. These corporations were all in cattle-related businesses. The stockholders of S, W, 7AL, and W & W decided to transfer their stock in these corporations to E in exchange for E stock in a sec. 351, I.R.C. 1954, 1All section references are to the Internal Revenue Code of 1954 as amended. transaction.

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Petitioner owned 45 percent of S and 100 percent of W. Gary, petitioner's nephew, controlled 7AL and GW. W and GW each owned 50 percent of W & W. These corporations were all in cattle-related businesses. The stockholders of S, W, 7AL, and W & W decided to transfer their stock in these corporations to E in exchange for E stock in a sec. 351, I.R.C. 1954, 1All section references are to the Internal Revenue Code of 1954 as amended. transaction. Beginning with book value as a basis for comparing their corporations, petitioner and Gary negotiated to determine the relative value of their…

1Opinion of the Court

Irvin Weisbart and Letty Weisbart, Petitioners v. Commissioner of Internal Revenue, Respondent

Weisbart v. Commissioner

Docket No. 8926-80

United States Tax Court

79 T.C. 521; 1982 U.S. Tax Ct. LEXIS 37; 79 T.C. No. 34;

September 23, 1982, Filed

Decision will be entered for the petitioners.

Petitioner owned 45 percent of S and 100 percent of W. Gary, petitioner's nephew, controlled 7AL and GW. W and GW each owned 50 percent of W & W. These corporations were all in cattle-related businesses. The stockholders of S, W, 7AL, and W & W decided to transfer their stock in these corporations to E in…

2Cases cited8 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Estate of Craft v. CommissionerUnited States Tax Court · 1977
  3. Ciaio v. CommissionerUnited States Tax Court · 1967
  4. Peterson Machine Tool, Inc. v. CommissionerUnited States Tax Court · 1982
  5. Cornelius Cotton Mills v. CommissionerUnited States Board of Tax Appeals · 1926

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