Hayden v. Commissioner

52 T.C. 1112, 1969 U.S. Tax Ct. LEXIS 50
CourtUnited States Tax Court
DecidedSeptember 30, 1969
DocketDocket Nos. 6177-66, 6178-66, 6179-66, 6180-66
StatusPublished
Cited by15 cases

This text of 52 T.C. 1112 (Hayden v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hayden v. Commissioner, 52 T.C. 1112, 1969 U.S. Tax Ct. LEXIS 50 (tax 1969).

Opinion

OPINION

The initial issue presented for decision is whether Spectacular Shows, Inc., adopted a plan meeting the requirements of section 1244(c) (1) (A) and the underlying regulations thereto. If that issue is determined in the affirmative, we must further decide whether all or any part of the stock issued to petitioners by Spectacular Shows, Inc., was issued pursuant to such plan. There is no question as to the other statutory requirements with respect to section 1244 stock.

Section 1244, the pertinent portions of which are set forth in the footnote below,4 was enacted to encourage the flow of new funds into small businesses. H. Rept. No. 2198, 85th Cong., 2d Sess., p. 4 (1959), 1959-2 C.B. 711. In effectuating this purpose, section 1244 provides ordinary-loss treatment where the original holder of what is termed “section 1244 stock” realizes a loss on such stock.

Section 1244(c) (1) supplies the definition of “section 1244 stock.” Initially, it provides that the term “section 1244 stock” means common stock in a domestic corporation if such corporation adopted a plan after June 80, 1958, to offer such stock for a specified period ending not later than 2 years after the date such plan was adopted. Sec. 1244(c)(1)(A).

Section 1244(e) provides that the Secretary or his delegate shall prescribe such regulations as may be necessary to carry out the purposes of this section. Section 1.1244(c)-l, Income Tax Kegs., as promulgated pursuant to this authority provides, in pertinent part, as follows:

Sec. 1.1244 (c)-l. Section 1244 stock defined.
(a) In general. In order that stock may qualify as section 1244 stock the requirements described in paragraphs (i>) through (h) of this section must be satisfied. * * *
(to) Oommom stoclc. Only common stock, either voting or nonvoting, in a domestic corporation may qualify as section 1244 stock. # * *
(c) Written plan. (1) The common stock must be issued pursuant to a written plan adopted by the corporation after June 30, 1958, to offer only such stock during a period specified in the plan ending not later than two years after the date the plan is adopted. * * * The plan must specifically state, in terms of dollars, the maximum amount to be received by the corporation in consideration for the stock to he issued pursuant thereto. * * *

Thus, by virtue of the above-quoted provisions of section 1244(e) (1) (A) and underlying regulations, there are presented the following initial requirements for qualification under section 1244:

1. The corporation must adopt a written plan sometime after June 30,1958, to offer only common stock.

2. Such plan must specifically state, in terms of dollars, the maximum amount to be received by the corporation in consideration for the stock to be issued pursuant thereto.

3. A period of time must be specified for the offering of stock, such period ending not later than 2 years after the date of the adoption of the plan.

The regulation’s requirement of having the plan in writing so as to evidence tangibly the intent to fall within the provisions of section .1244 finds direct support in the legislative history of section 1244. The House committee report provides, inter alia, that “Such plan jury could properly find or infer, beyond a reasonable doubt,’ that (1959), 1959-2 C.B. 114. This requirement of the regulation has been specifically upheld by us as a reasonable interpretation of section 1244. ’Wesley H. Morgan, 46 T.C. 878 (1966).

In our determination as to whether Spectacular Shows, Inc., adopted a valid written plan, we first examine the corporate minutes of the organization meeting held on May 21, 1960. The minutes record the adopted bylaws of the corporation which designate, inter alia, that the capital stock of the corporation shall be such as is set out in the certificate of incorporation. The original, May 19, 1960, certificate of incorporation, although it is not specifically stated therein, makes it quite clear that the incorporators intended to issue only 5,000 shares of common stock at a par value of $1 each; the only stock subscribed for by the incorporators is specifically stated to be common stock; we cannot find any possible way to interpret the certificate of incorporation as authorizing the issuance of preferred stock.

As stated in the original certificate of incorporation, the total authorized capital stock of the corporation was $5,000, to be divided into 5,000 shares at the par value of $1 each. Without anything else, it might be in the realm of speculation for us to determine whether the 5,000 shares were intended to be common stock or preferred stock; but there are further indications in the certificate which clarify this matter. In the portion of the certificate regarding stock subscriptions, it is designated that each of the three original incorporators was subscribing to 350 shares of common stock. That part of the subscription information regarding preferred stock for each of the incorporators was first typed in with the designation of “none.” At some time subsequent to the typing in of the response of “none,” the subscription information in the certificate relating to preferred stock was crossed out. Under that portion of the certificate regarding stock subscriptions there was a further informational request that the space below be used for any statements as to stock without par value, or where more than one class of stock was to be issued, or where one or more series was to be issued within a class of stock. The space below this request was left blank. All of these indications make it quite obvious that the original certificate of incorporation authorizes the issuance of only 5,000 shares of common stock and that no preferred stock was to be issued.

Eeferring back now to the minutes of the organization meeting on May 21, 1960, we find that there was some discussion by the board of directors specifically indicating their intent to adopt a plan to fall within the provisions of section 1244 and that all the stock being issued by the corporation was to be in accordance with this plan. The “plan” to which the minutes make reference is found in a handwritten document, dated May 21, 1960, which was prepared and signed by William Hayden as president of Spectacular Shows, Inc. The document provides as follows:

Spectacular Shows, Inc.
All of tlie attached stock is issued under Sec. 1244 and the maximum amount to be issued under the plan will be 5,000 shares at $1.00 per share.
All of this stock (5,000 shares) will be issued within 2 years and by no later than May, 1962.

Upon reviewing the minutes of the May 21,1960, meeting, the original certificate of incorporation, and the handwritten document dated May 21, 1960, it is our conclusion that these documents, when taken together, present a written plan meeting the requirements of section 1244(c) (1) (A) and underlying regulations thereto:

1. At some time after June 30, 1958, the corporation did adopt a written plan, as embodied in these documents, to offer only common stock to its shareholders.

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Hayden v. Commissioner
52 T.C. 1112 (U.S. Tax Court, 1969)

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Bluebook (online)
52 T.C. 1112, 1969 U.S. Tax Ct. LEXIS 50, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayden-v-commissioner-tax-1969.