ADAIR v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 3881-79, 9235-79, 22777-81, 22778-81.

54 T.C.M. 705 (1987)

T.C. Memo. 1987-494

William O. Adair and Florence O. Adair, et al., Petitioners v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

Filed September 28, 1987.


Attorney(s) appearing for the Case

H. G. Sparrow III and Thomas D. Hammerschmidt, Jr., for the petitioners in Docket No. 3881-79. Stephen Wasinger and Richard S. Soble, for the petitioners in Docket No. 9235-79. Michael K. Cavanaugh and Robert E. Arroyo, 233 S. Wacker Dr., Chicago, Ill., for the petitioner in Docket Nos. 22777-81 and 22778-81. Jaqueline M. Hotz, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

The facts of this case were previously set forth at T.C. Memo. 1985-392, which along with the stipulated facts are incorporated by reference and will be summarized here only as necessary for this opinion. The remaining issue is the fair market value of Clow Corporation $6 Series A convertible preferred stock (Series A preferred stock) on March 2, 1973, and March...

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