Crowe v. Commissioner
United States Tax Court
As a condition to his purchase of one-half the stock of Rayburn Land Co., the petitioner was required by the other shareholder to grant that shareholder a unilateral option for 5 years whereby the latter shareholder could reacquire the petitioner's 50-percent stock interest.
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As a condition to his purchase of one-half the stock of Rayburn Land Co., the petitioner was required by the other shareholder to grant that shareholder a unilateral option for 5 years whereby the latter shareholder could reacquire the petitioner's 50-percent stock interest. Prior to the completion of construction and following disagreements over development policy, the latter shareholder exercised the option, purchased the petitioner's stock, and continued to operate the corporation. Held, Rayburn Land Co. was not a collapsible corporation within the meaning of sec. 341 since the view…
1Opinion of the Court
Sterrett, Judge:
The respondent determined a deficiency of $43,240.09 in the Federal income taxes of petitioners for the calendar year 1966. The sole issue for decision is whether the gain on the sale of stock of Rayburn Land Co. is taxable as ordinary income under the provisions of section 341, I.R.C. 1954,1 or as long-term capital gain.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.
Joseph M. Crowe and Kathryn K. Crowe are husband and wife who, at the time…
2Cases cited9 opinions
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- Farber v. CommissionerUnited States Tax Court · 1961
- Jack and Celia Farber v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Rechner v. CommissionerUnited States Tax Court · 1958
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3Cited by5 opinions
- Manassas Airport Industrial Park, Inc. v. CommissionerUnited States Tax Court · 1976
- Crowe v. CommissionerUnited States Tax Court · 1974
- Felix v. CommissionerUnited States Tax Court · 1981
- Manassas Airport Industrial Park, Inc. v. CommissionerUnited States Tax Court · 1976
- Zorn v. CommissionerUnited States Tax Court · 1976