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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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