Francis v. Commissioner
United States Tax Court
In 1974 petitioners formed a corporation that issued stock to them based on a written plan. The corporation issued stock in exchange for $ 50,000. The stock issuance plan did not limit the period during which the stock could be issued. The plan also failed to state the maximum amount of consideration that could be paid for the stock. Held, the stock does not qualify as section 1244 stock.
1Opinion of the Court
RAYMOND J. AND MARIA E. FRANCIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Francis v. Commissioner
Docket No. 18745-81.
United States Tax Court
T.C. Memo 1987-362; 1987 Tax Ct. Memo LEXIS 362; 53 T.C.M. (CCH) 1427; T.C.M. (RIA) 87362;
July 23, 1987.
In 1974 petitioners formed a corporation that issued stock to them based on a written plan. The corporation issued stock in exchange for $ 50,000. The stock issuance plan did not limit the period during which the stock could be issued. The plan also failed to state the maximum amount of consideration that could be paid for the stock.…
2Cases cited8 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Casco Bank & Trust Co. v. United StatesCourt of Appeals for the First Circuit · 1976
- Warner v. CommissionerUnited States Tax Court · 1967
- James A. And Audrey J. Warner v. Commissioner of Internal Revenue, Jerrie D. And Leta J. Schooley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Siebert v. CommissionerUnited States Tax Court · 1969
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