Abbott v. Commissioner
United States Tax Court
Petitioner and X each owned 50 percent of the stock in A, B, C and D corporations. A and B corporations were managed by petitioner and C and D corporations were managed by X. B corporation was in financial difficulty.
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Petitioner and X each owned 50 percent of the stock in A, B, C and D corporations. A and B corporations were managed by petitioner and C and D corporations were managed by X. B corporation was in financial difficulty. Pursuant to a contract made by petitioner, X, and A, B, C and D corporations, X transferred his stock in A and B corporations respectively to A and petitioner in exchange for certain assets and cash and petitioner transferred his stock in C and D corporations as a capital contribution to B corporation which thereafter transferred the stock respectively to C and D corporations…
1Opinion of the Court
Thomas F. Abbott, Jr., and Edith Abbott v. Commissioner.
Abbott v. Commissioner
Docket No. 474-62.
United States Tax Court
T.C. Memo 1964-65; 1964 Tax Ct. Memo LEXIS 269; 23 T.C.M. (CCH) 445; T.C.M. (RIA) 64065;
March 13, 1964
Petitioner and X each owned 50 percent of the stock in A, B, C and D corporations. A and B corporations were managed by petitioner and C and D corporations were managed by X. B corporation was in financial difficulty. Pursuant to a contract made by petitioner, X, and A, B, C and D corporations, X transferred his stock in A and B corporations respectively to A and petitioner…
2Cases cited9 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- United States v. IshamSupreme Court of the United States · 1873
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983