Mathis v. Commissioner
United States Tax Court
Held, an initial downpayment and subsequent installment payments made by a corporation in connection with the acquisition of its preferred stock were payments on the overall purchase price of the stock under a valid redemption contract, not dividend distributions; they resulted in the complete termination of the shareholder's interest in the distributing corporation, thus qualifying the transaction for capital gains treatment under sec. 302(a), I.R.C. 1954.
1Opinion of the Court
Estate of Oscar L. Mathis, Deceased, Josie L. Mathis, Administratrix, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Mathis v. Commissioner
Docket Nos. 2036-64, 2037-64, 2038-64
United States Tax Court
47 T.C. 248; 1966 U.S. Tax Ct. LEXIS 12;
December 5, 1966, Filed
Decisions will be entered under Rule 50.
Held, an initial downpayment and subsequent installment payments made by a corporation in connection with the acquisition of its preferred stock were payments on the overall purchase price of the stock under a valid redemption contract, not dividend distributions; they…
2Cases cited4 opinions
- Danielson v. CommissionerUnited States Tax Court · 1965
- Gilmore v. CommissionerUnited States Tax Court · 1956
- Mathis v. CommissionerUnited States Tax Court · 1966
- Warren Nat. Bank v. CommissionerCourt of Appeals for the Third Circuit · 1932