2
After concessions by the parties, the issue for decision is
whether Shefferman & Bigelson Co. (S&B) distributed a dividend to
Thor Energy Resources, Inc. (Thor), in the amount of
$1,245,880.36, and if so, the effect of that distribution on
Thor's sale of S&B stock. We hold that the $1,245,880.36
constitutes a portion of the sale price of the S&B stock, and S&B
did not distribute a dividend in that amount.
All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
FINDINGS OF FACT
Some of the facts are stipulated and are so found. We
incorporate by reference the stipulation of facts and attached
exhibits.
Petitioner is Thor and subsidiaries. Thor is a corporation
organized under the laws of the State of Delaware and is engaged
through its subsidiaries in oil and gas exploration and
production, with its principal business location in Tyler, Texas.
Thor's board of directors included LaVelle D. Fender, David M.
Fender, Harris R. Fender, Jr., B. Bruce Freitag, and Leroy
LaSalle. David M. Fender served as Thor's president and chief
executive officer.
S&B is a corporation organized under the laws of the
District of Columbia on January 25, 1960, and its principal
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011