Estate of Estroff v. Commissioner
United States Tax Court
Maxwell Estroff owned 7,486 shares of stock of First Railroad and Banking Co. of Georgia, and his wife, Naomi, owned 14,073 shares. Maxwell entered into an agreement with his friend and longtime business associate, Fink, to sell the 21,559 shares to fink at market price and Fink agreed to sell the shares back to Estroff at the same price in not less than 30 days.
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Maxwell Estroff owned 7,486 shares of stock of First Railroad and Banking Co. of Georgia, and his wife, Naomi, owned 14,073 shares. Maxwell entered into an agreement with his friend and longtime business associate, Fink, to sell the 21,559 shares to fink at market price and Fink agreed to sell the shares back to Estroff at the same price in not less than 30 days. Estroff loaned Fink $135,000, without interest, to buy the stock. 34 days later Fink sold the 21,559 shares to Estroff for the same price he paid for them and used the proceeds to repay the loan to Estroff. The Estroffs had a large…
1Opinion of the Court
ESTATE OF MAXWELL J. ESTROFF, Deceased, NAOMI ESTROFF and DALE TOPOREK, Executrixes, and NAOMI ESTROFF, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Estroff v. Commissioner
Docket No. 17880-80
United States Tax Court
T.C. Memo 1983-666; 1983 Tax Ct. Memo LEXIS 120; 47 T.C.M. (CCH) 234; T.C.M. (RIA) 83666;
November 3, 1983.
Maxwell Estroff owned 7,486 shares of stock of First Railroad and Banking Co. of Georgia, and his wife, Naomi, owned 14,073 shares. Maxwell entered into an agreement with his friend and longtime business associate, Fink, to sell the 21,559 shares to fink at market…
2Cases cited10 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- McWilliams v. CommissionerSupreme Court of the United States · 1947
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