Stone v. Comissioner
United States Tax Court
Petitioners' decedent in the taxable year 1948 sold certain stock purchase warrants acquired in 1947 from the Follansbee Steel Corporation of which he was the president. At the time of the acquisition of the warrants they had a fair market value in excess of the price paid therefor and the warrants were immediately negotiable.
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Petitioners' decedent in the taxable year 1948 sold certain stock purchase warrants acquired in 1947 from the Follansbee Steel Corporation of which he was the president. At the time of the acquisition of the warrants they had a fair market value in excess of the price paid therefor and the warrants were immediately negotiable. Held: 1. The warrants were capital assets as defined by section 117 (a) (1), I. R. C. 2. The decedent's base for determining gain or loss on the sale of such stock warrants in the taxable year 1948 is the amount paid therefor, increased by the amount included as…
1Opinion of the Court
OPINION.
LeMire, Judge:
The question presented is whether the net consideration received by petitioners’ decedent, Lauson Stone, on the sale in 1948 of certain stock warrants is taxable as additional compensation or as capital gain.
The petitioners’ decedent was first employed as president and chief executive officer of the Follansbee Steel Corporation on October 2'6, 1942. On March 31, 1944, the decedent entered into a written contract of employment with such corporation for a period of 5 years from January 1, 1943, which provided that his compensation was not to be less than $50,000 per year.…
2Cases cited2 opinions
- Helvering v. San Joaquin Fruit & Investment Co.Supreme Court of the United States · 1936
- Commissioner v. SmithSupreme Court of the United States · 1945
3Cited by25 opinions
- Frank v. CommissionerUnited States Tax Court · 1970
- Le Vant v. CommissionerUnited States Tax Court · 1965
- Commissioner of Internal Revenue v. Stone's EstateCourt of Appeals for the Third Circuit · 1954
- Shamburger v. CommissionerUnited States Tax Court · 1973
- Rosenberg v. CommissionerUnited States Tax Court · 1953
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