Legal Opinion

Dunlap v. Commissioner

United States Tax Court

Decided September 24, 1980No. Docket Nos. 6726-76, 7858-76, 2414-77, 2779-77, 5351-77, 9438-77Published

Petitioner Dunlap, together with one Weil, were officers and shareholders of petitioner Hawkeye Bancorporation. Hawkeye wished to acquire the stock of Jasper Bank but required prior Federal Reserve Board (F.R.B.) approval, and the Jasper stockholders were unwilling to wait.

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Petitioner Dunlap, together with one Weil, were officers and shareholders of petitioner Hawkeye Bancorporation. Hawkeye wished to acquire the stock of Jasper Bank but required prior Federal Reserve Board (F.R.B.) approval, and the Jasper stockholders were unwilling to wait. Accordingly, Dunlap and Weil purchased the Jasper stock, most of it under an installment payment agreement, for a total price of $ 4,072,190, with Dunlap taking an 83.6-percent interest and concurrently with the purchase of the bulk of the stock, agreed with Hawkeye to resell all the stock to Hawkeye for $ 4,150,000 if and…

1Opinion of the Court

Paul D. Dunlap and Shirley A. Dunlap, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Dunlap v. Commissioner

Docket Nos. 6726-76, 7858-76, 2414-77, 2779-77, 5351-77, 9438-77

United States Tax Court

74 T.C. 1377; 1980 U.S. Tax Ct. LEXIS 53;

September 24, 1980, Filed

Decisions will be entered under Rule 155.

Petitioner Dunlap, together with one Weil, were officers and shareholders of petitioner Hawkeye Bancorporation. Hawkeye wished to acquire the stock of Jasper Bank but required prior Federal Reserve Board (F.R.B.) approval, and the Jasper stockholders were unwilling to wait.…

2Cases cited29 opinions

  1. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  2. Commissioner v. BrownSupreme Court of the United States · 1965
  3. Woodward v. CommissionerSupreme Court of the United States · 1970
  4. Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
  5. Estate of Horvath v. CommissionerUnited States Tax Court · 1973

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