¶1concurring: I agree not only with the majority opinion, but also with Judge Chiechi’s concurring opinion and with that part of Judge Beghe’s concurring opinion that relates to the historical and policy reasons for leaving preexisting redemption tax law intact.
102 T.C. 522
Arnes v. Commissioner
Decided April 5, 1994
United States Tax Court · decided 1994-04-05
H and W were married and jointly owned 100 percent of M, which owned and operated a McDonald's restaurant. H and W separated. Held: No constructive dividend resulted to H from M's redemption of W's stock, because H did not have a primary and unconditional obligation to purchase W's stock. See Edler v. Commissioner, 727 F.2d 857 (9th Cir. 1984), affg. T.C. Memo. 1982-67. 2.
Cited by 8 later decisions — most recently June 2000
1 federal appellate ·
Good law ✅— No negative treatment on recordhow we know
Decided 1994-04-05
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