114 T.C. No. 2
UNITED STATES TAX COURT
CAROL M. READ, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 19001-97, 19322-97, Filed February 4, 2000.
19328-97.
W and H, who were married, owned all of the vot-
ing, and virtually all of the nonvoting, stock of X
corporation (X). They divorced, and the final judgment
dissolving their marriage (divorce judgment) ordered
(1) that W sell and convey to H, or at H's election to
X or X's ESOP plan, all of her X stock, (2) that H, or
at H's election X or X's ESOP plan, pay a stated amount
of cash to W simultaneously with the sale and convey-
ance of such stock, and (3) that as additional consid-
eration H, or at H's election X or X's ESOP plan,
deliver to W a promissory note bearing 9-percent inter-
est for the balance of the purchase price of that
stock. Pursuant to the divorce judgment, H elected
(1) that the sale and conveyance of all of W's X stock
1Cases of the following petitioners are consolidated here-
with: Mulberry Motor Parts, Inc., docket No. 19322-97, and
William A. Read, docket No. 19328-97.
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