Legal Opinion

Watson v. Commissioner

United States Tax Court

Decided November 30, 1960No. Docket Nos. 55521, 56225, 56237, 56255, 56260, 56268, 56269, 56271, 56276, 56329, 57397Unpublished

The petitioners are executive-employees of R & R corporation. Early in 1943, the stock of R & R corporation consisted of 15,000 shares of common stock, all of which was held by members of 2 families and an estate. In 1943, the corporation issued 15,000 shares of preferred stock as a stock dividend on the common stock. Thereafter, new common stock was issued.

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The petitioners are executive-employees of R & R corporation. Early in 1943, the stock of R & R corporation consisted of 15,000 shares of common stock, all of which was held by members of 2 families and an estate. In 1943, the corporation issued 15,000 shares of preferred stock as a stock dividend on the common stock. Thereafter, new common stock was issued. The members of the families and the estate, in 1943, sold 9,400 shares of new common stock to executive employees, including petitioners, and 2,400 shares to the R & R corporation to be held in its treasury. In subsequent years, some of…

1Opinion of the Court

Paul E. Watson, et al. 1 v. Commissioner.

Watson v. Commissioner

Docket Nos. 55521, 56225, 56237, 56255, 56260, 56268, 56269, 56271, 56276, 56329, 57397.

United States Tax Court

T.C. Memo 1960-255; 1960 Tax Ct. Memo LEXIS 31; 19 T.C.M. (CCH) 1409; T.C.M. (RIA) 60255;

November 30, 1960

The petitioners are executive-employees of R & R corporation. Early in 1943, the stock of R & R corporation consisted of 15,000 shares of common stock, all of which was held by members of 2 families and an estate. In 1943, the corporation issued 15,000 shares of preferred stock as a stock dividend on the common stock.…

2Cases cited63 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Helvering v. CliffordSupreme Court of the United States · 1940
  4. Lucas v. EarlSupreme Court of the United States · 1930
  5. Helvering v. HorstSupreme Court of the United States · 1940

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