Legal Opinion

O'Madigan v. Commissioner

United States Tax Court

Decided October 7, 1960No. Docket No. 66433UnpublishedCited by 1 opinion

1. Petitioner, in 1953, was an executive of General Motors. He undertook to obtain a dealership in St. Louis. Dan O'Madigan, Inc., was organized in 1953 to acquire the Pontiac dealership, and it issued class A and class B stock. General Motors purchased the class A stock. Petitioner purchased the class B, nonvoting stock, for $85,000. Petitioner was president.

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1. Petitioner, in 1953, was an executive of General Motors. He undertook to obtain a dealership in St. Louis. Dan O'Madigan, Inc., was organized in 1953 to acquire the Pontiac dealership, and it issued class A and class B stock. General Motors purchased the class A stock. Petitioner purchased the class B, nonvoting stock, for $85,000. Petitioner was president. Within one year, General Motors, in 1954, exercised its right under an agreement to dismiss the petitioner and advised him that his class B stock was worthless. After negotiations, General Motors paid $10,000 to petitioner, and…

1Opinion of the Court

Daniel O'Madigan, Jr., and Marjorie O'Madigan v. Commissioner.

O'Madigan v. Commissioner

Docket No. 66433.

United States Tax Court

T.C. Memo 1960-212; 1960 Tax Ct. Memo LEXIS 77; 19 T.C.M. (CCH) 1178; T.C.M. (RIA) 60212;

October 7, 1960

1. Petitioner, in 1953, was an executive of General Motors. He undertook to obtain a dealership in St. Louis. Dan O'Madigan, Inc., was organized in 1953 to acquire the Pontiac dealership, and it issued class A and class B stock. General Motors purchased the class A stock. Petitioner purchased the class B, nonvoting stock, for $85,000. Petitioner was president.…

2Cases cited17 opinions

  1. Helvering v. HammelSupreme Court of the United States · 1941
  2. Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  3. Hazard v. CommissionerUnited States Tax Court · 1946
  4. Lagreide v. CommissionerUnited States Tax Court · 1954
  5. Smith v. CommissionerUnited States Tax Court · 1953

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

3Cited by1 opinion

  1. Millar v. CommissionerUnited States Tax Court · 1975

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