Michael Ferguson, Valene Ferguson, Roger N. Ferguson and Sybil Ferguson v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that the shareholder recognizes income from a stock sale where acquisition is “practically certain to occur”, rather than the subject of “a mere anticipation or expectation”, before the shareholder donates stock
• finding that the shareholder recognizes income from a stock sale where acquisition is “practically certain to occur”, rather than the subject of “a mere anticipation or expectation”, before the shareholder donates stock
• finding an assignment of income where stock was donated after tender offer had effectively been completed and it was “most unlikely” that the offer would be rejected

Source: CourtListener parenthetical corpus (CC0).