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