Crow-Burlingame Co. v. Commissioner
United States Tax Court
Held: Stock which was sold to the employees of subsidiary corporations subject to a repurchase option was "excluded stock" within the meaning of sec. 1563(c)(2)(A)(iii), I.R.C. 1954. The repurchase option favored the parent corporation indirectly even though a third corporation, owned principally by employees of the parent and the subsidiaries, was formally designated as the optionee.
1Opinion of the Court
Crow-Burlingame Co. of Pine Bluff, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Crow-Burlingame Co. v. Commissioner
Docket Nos. 3132-74, 3133-74, 3134-74, 3135-74, 3136-74, 3137-74, 3138-74, 3139-74, 3140-74, 3141-74, 3142-74
United States Tax Court
65 T.C. 785; 1976 U.S. Tax Ct. LEXIS 174;
January 22, 1976, Filed
Decisions will be entered for the respondent.
Held: Stock which was sold to the employees of subsidiary corporations subject to a repurchase option was "excluded stock" within the meaning of sec. 1563(c)(2)(A)(iii), I.R.C. 1954. The repurchase option favored the…
2Cases cited3 opinions
- Barton Naphtha Co. v. CommissionerUnited States Tax Court · 1971
- Mid-America Industries, Inc., a Delaware Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1973
- Crow-Burlingame Co. v. CommissionerUnited States Tax Court · 1976