Blount v. Commissioner
United States Tax Court
The petitioner and his family owned 40 percent of the outstanding stock in a corporation; two other family groups, headed by his brother and brother-in-law, owned most of the balance of the stock.
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The petitioner and his family owned 40 percent of the outstanding stock in a corporation; two other family groups, headed by his brother and brother-in-law, owned most of the balance of the stock. The petitioner, his brother, and his brother-in-law entered into an agreement with the company, which provided for their retirement with a pension, and further provided that each of them could, at his election, have up to a certain stated amount of his stock redeemed by the corporation each year. This plan was not designed to effectuate any valid business purpose of the corporation. Held, the…
1Opinion of the Court
Simpson, Judge:
The respondent determined deficiencies in the petitioners’ income tax as follows:
TYJS Deficiency
12/31/60_$3,078. 46
12/31/61_ 3,624.99
12/31/62_ 2,141.22
12/31/63_ 2,264.65
The sole question for decision is whether the distributions by the Blount Lumber Co. to the petitioners in redemption of their stock were taxable as a dividend. The petitioners have conceded another issue raised by the statutory notice of deficiency, and the third issue, relating to the deduction of medical expenses, depends solely on our resolution of the principal issue.
FINDINGS OF FACT
Some of the facts have…
2Cases cited11 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Eva D. Bradbury v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1962
- Decker v. CommissionerUnited States Tax Court · 1959
- Lewis v. CommissionerUnited States Tax Court · 1960
- Beatrice Levin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
6 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- McDonald v. CommissionerUnited States Tax Court · 1969
- Howard P. Blount and Dolly H. Blount v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Blount v. CommissionerUnited States Tax Court · 1969
- McDonald v. CommissionerUnited States Tax Court · 1969