Stuart V.
This text of 2015 U.S. Tax Ct. LEXIS 17 (Stuart V.) 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.
Opinion
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*17 v. ) Docket No. 1685-11, 1686-11,
) 1687-11, 1688-11.
COMMISSIONER OF INTERNAL REVENUE, )
)
Respondent )
ORDER
For cause, it is
ORDERED: That the Court's Opinion filed April 1, 2015,
(2015) is hereby amended as follows:
On page 8, beginning on line 11 and continuing to line 12, change the words "Share Purchase Agreement" to the words "share purchase agreement".
On page 11, on line 18, insert a comma between the words "on" and "August", so the last three words on the line read: "on, August 7,".
On page 30, on line 14, delete the last word on the line, "transfers", and substitute, instead, the words "a transfer".
On page 35, in footnote 7, at the end of the sixth line ofthe quoted material, add the following: [The second comma in the second to last line (which appears in the original) appears to be an error. The final phrase of the sentence likely should read: "not the Tax Court under
On page 41, beginning on line 7, delete the following sentence: Value, however, does not include an executory promise other than a promise made in the ordinary course ofthe promisor's business to furnish support to the debtor or to another. Substitute, instead, the following sentence: Value, however, does*18 not
SERVED Apr 15 2015
- 2 -
include an unperformed promise made otherwise than in the ordinary course ofthe promisor's business to furnish support to the debtor or to another.
On page 44, on line 12, strike the word "account" and substitute, instead, the word "agreement".
On page 46, beginning on line 10, delete the following sentence: Little Salt received no value, much less reasonably equivalent value, on account ofthe transfer. Substitute, instead, the following sentence: Little Salt did not receive reasonably equivalent value on account ofthe transfer.
On page 57, on line 13, strike the amount "$467,721" and substitute, instead, the amount "$358,826".
On page 63, strike the decision line "Decisions will be entered for respondent." and substitute, instead, "Decisions will be entered under
(Signed) James S. Halpern
Judge
Dated: Washington, D.C.
April 15, 2015
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2015 U.S. Tax Ct. LEXIS 17, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stuart-v-tax-2015.