# Frontier Sav. Asso. v. Commissioner

> United States Tax Court · September 24, 1986 · 87 T.C. 665

URL: https://www.frixlaw.com/law-library/cases/4485594

## Case

- **Full name:** Frontier Savings Association and Subsidiaries v. Commissioner of Internal Revenue, Respondent Frontier Savings and Loan Association v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** September 24, 1986
- **Citations:** 87 T.C. 665; 87 T.C. No. 40; 1986 U.S. Tax Ct. LEXIS 47
- **Precedential status:** Published
- **Opinion:** Concurrence by Hamblen
- **Judges:** Swift,Goffe,Chabot,Nims,Whitaker,Korner,Shields,Hamblen,Cohen,Clapp,Jacobs,Simpson,Gerber,Wright,Williams,Hamblen,Sterrett,Cohen,Jacobs
- **Cited by:** 11 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4485594

## Opinion text

HAMBLEN, J., concurring: I concur in the conclusion of the majority based upon the limited factual circumstances involved. If a discretionary act of the board of directors of a shareholder corporation to redeem stock dividends becomes a routine matter, it might, in my opinion, develop into an “option” that arises after the distribution or a distribution pursuant to a “plan.” See secs. 1.305-2(a) and 1.305-3(b), Income Tax Regs. In such a situation, it seems the redemptions might be periodic rather than isolated. The broad rules of section 305 could invoke different considerations under other circumstances.
Sterrett, Cohen, and JACOBS, JJ., agree with this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4485594. Public record. Not legal advice.