Legal Opinion
Gerald A. and Henrietta v. Rauenhorst v. Commissioner
United States Tax Court
Decided October 7, 2002No. 1982-00Unknown
1Opinion of the Court
119 T.C. No. 9
UNITED STATES TAX COURT GERALD A. AND HENRIETTA V. RAUENHORST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1982-00. Filed October 7, 2002. Ps owned stock warrants in NMG. WCP sent a letter to NMG regarding its intention to purchase all the issued and outstanding stock of NMG. Ps then assigned their warrants to four charitable institutions. At the time of the assignments, the donees were under no legal obligation, and could not be compelled, to sell the warrants. The donees subsequently sold their warrants to WCP. R determined that the contributions by…
2Cases cited64 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
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