Michael Ferguson and Valene Ferguson - Page 1

                                   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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