Coloman v. Commissioner
United States Tax Court
1. Held: A corporation in which the petitioners held stock did not adopt a "plan" to offer stock pursuant to section 1244(c) (1), and the petitioners are therefore not entitled to the benefits of section 1244. 2. Held: The petitioners have failed to prove that their basis in stock that became worthless was in excess of zero. Stephen A. Pace, for the petitioners. George W. McDonald, for the respondent.
1Opinion of the Court
EUGENE COLOMAN, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Coloman v. Commissioner
Docket Nos. 3667-72, 3668-72 3670-72, 3671-72.
United States Tax Court
T.C. Memo 1974-78; 1974 Tax Ct. Memo LEXIS 241; 33 T.C.M. (CCH) 411; T.C.M. (RIA) 74078;
March 28, 1974, Filed.
1. Held: A corporation in which the petitioners held stock did not adopt a "plan" to offer stock pursuant to section 1244(c) (1), and the petitioners are therefore not entitled to the benefits of section 1244.
2. Held: The petitioners have failed to prove that their basis in stock that became worthless was in…
2Cases cited5 opinions
- Pierre Godart and Suzanne Godart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Alameda Realty Corp. v. CommissionerUnited States Tax Court · 1964
- Godart v. CommissionerUnited States Tax Court · 1969
- Spiegel v. CommissionerUnited States Tax Court · 1968
- Rickey v. CommissionerUnited States Tax Court · 1970
3Cited by1 opinion
- Jupiter Corp. v. United StatesUnited States Court of Claims · 1983