Legal Opinion

Abbott v. Commissioner

United States Tax Court

Decided March 13, 1964No. Docket No. 474-62UnpublishedCited by 1 opinion

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  4. United States v. IshamSupreme Court of the United States · 1873
  5. American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948

4 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983

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