108 T.C. No. 14
UNITED STATES TAX COURT
MICHAEL FERGUSON AND VALENE FERGUSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
ROGER N. FERGUSON AND SYBIL FERGUSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 21808-93, 18250-94. Filed April 28, 1997.
Held: Ps donated to various charitable
organizations (the Charities) appreciated stock in C1.
Prior to the gifts, C1 and C2 entered into a merger
agreement, C2 made a tender offer for the shares of C1,
and shares of C1 sufficient to approve the merger were
tendered or guaranteed. The Charities subsequently
sold the stock of C1 received from Ps pursuant to the
tender offer. Ps are taxable on the gain in the stock
transferred to the Charities under the anticipatory
assignment of income doctrine.
David R. Bosse, for petitioners.
Robert First (specially recognized) for petitioners.
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