Legal Opinion

Downer v. Commissioner

United States Tax Court

Decided April 27, 1967No. Docket No. 2082-65Published

In 1961, petitioner transferred 100,000 shares of stock in the corporation to an employee of the corporation to induce him to continue to work for the corporation. Petitioner retained 325,000 shares. Held, the transaction was a "sale or exchange" and petitioner sustained a capital loss.

1Opinion of the Court

J. K. Downer and Edith Downer, Petitioners v. Commissioner of Internal Revenue, Respondent

Downer v. Commissioner

Docket No. 2082-65

United States Tax Court

48 T.C. 86; 1967 U.S. Tax Ct. LEXIS 113;

April 27, 1967, Filed

Decision will be entered under Rule 50.

In 1961, petitioner transferred 100,000 shares of stock in the corporation to an employee of the corporation to induce him to continue to work for the corporation. Petitioner retained 325,000 shares. Held, the transaction was a "sale or exchange" and petitioner sustained a capital loss.

Jerry D. Luptak and Basil M. Briggs, for the petitioners.

Cha…

Also in this document: Dissent.

2Cases cited31 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. United States v. DavisSupreme Court of the United States · 1962
  3. Howell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1934
  4. United States v. General Shoe CorporationCourt of Appeals for the Sixth Circuit · 1960
  5. Hewett v. CommissionerUnited States Tax Court · 1967

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