Legal Opinion

Johnson v. Commissioner

United States Tax Court

Decided April 8, 1982No. Docket No. 15102-80Published

T was the owner of 120 shares of class B stock of Missouri Pacific Railroad Co. (MoPac). There were only two classes of stock, A and B. One share of each class was entitled to one vote. The A stock was entitled to a noncumulative annual preferred dividend not to exceed $ 5 per share and a preferred distribution limited to $ 100 per share on liquidation.

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T was the owner of 120 shares of class B stock of Missouri Pacific Railroad Co. (MoPac). There were only two classes of stock, A and B. One share of each class was entitled to one vote. The A stock was entitled to a noncumulative annual preferred dividend not to exceed $ 5 per share and a preferred distribution limited to $ 100 per share on liquidation. The B stock was entitled, without limitation, to annual dividends and distribution on liquidation after the requirements of the A stock were satisfied. In substance, the B stockholders were the equity owners of MoPac. However, approximately 98…

1Opinion of the Court

James Hervey Johnson, Petitioner v. Commissioner of Internal Revenue, Respondent

Johnson v. Commissioner

Docket No. 15102-80

United States Tax Court

78 T.C. 564; 1982 U.S. Tax Ct. LEXIS 115; 78 T.C. No. 39;

April 8, 1982, Filed

Decision will be entered under Rule 155.

T was the owner of 120 shares of class B stock of Missouri Pacific Railroad Co. (MoPac). There were only two classes of stock, A and B. One share of each class was entitled to one vote. The A stock was entitled to a noncumulative annual preferred dividend not to exceed $ 5 per share and a preferred distribution limited to $ 100 per…

2Cases cited19 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
  3. Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
  4. American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
  5. Zenz v. QuinlivanCourt of Appeals for the Sixth Circuit · 1954

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