M. Conley Co. v. Commissioner
United States Tax Court
In years prior to 1941 the petitioner purchased from some of its stockholders their shares of stock in the corporation which it thereafter carried as treasury stock. It was the policy of the corporation to have its shares owned by persons who were actively connected with the company as officers or employees, and the purchases were made to keep them from falling into the hands of persons not so connected with the corporation.
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In years prior to 1941 the petitioner purchased from some of its stockholders their shares of stock in the corporation which it thereafter carried as treasury stock. It was the policy of the corporation to have its shares owned by persons who were actively connected with the company as officers or employees, and the purchases were made to keep them from falling into the hands of persons not so connected with the corporation. In 1941 it sold some of these shares to its officers and employees at a profit. Held, that the corporation was dealing in its own shares as it might have dealt in the…
1Opinion of the Court
The M. Conley Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
M. Conley Co. v. Commissioner
Docket No. 5833
United States Tax Court
6 T.C. 250; 1946 U.S. Tax Ct. LEXIS 291;
February 25, 1946, Promulgated
Decision will be entered for the respondent.
In years prior to 1941 the petitioner purchased from some of its stockholders their shares of stock in the corporation which it thereafter carried as treasury stock. It was the policy of the corporation to have its shares owned by persons who were actively connected with the company as officers or employees, and the purchases were…
Also in this document: Concurrence · Murdock; Concurrence · Opper.
2Cases cited2 opinions
- Cluett, Peabody & Co. v. CommissionerUnited States Tax Court · 1944
- M. Conley Co. v. CommissionerUnited States Tax Court · 1946