Legal Opinion

Crow-Burlingame Co. v. Commissioner

United States Tax Court

Decided January 22, 1976No. Docket Nos. 3132-74, 3133-74, 3134-74, 3135-74, 3136-74, 3137-74, 3138-74, 3139-74, 3140-74, 3141-74, 3142-74Published

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

  1. Barton Naphtha Co. v. CommissionerUnited States Tax Court · 1971
  2. Mid-America Industries, Inc., a Delaware Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1973
  3. Crow-Burlingame Co. v. CommissionerUnited States Tax Court · 1976

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