Legal Opinion

Hawke v. Commissioner

United States Board of Tax Appeals

Decided March 31, 1937No. Docket Nos. 76507, 76508Published

1. For a number of years prior to 1930 the petitioner was employed as manager of a branch store of J. C. Penney Co. at Modesto, California, under contracts which enabled him to purchase shares of stock of the company at prices less than their fair market value. In 1928 and 1929 he acquired under the contracts a number of shares of the stock at much less than their fair market value.

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1. For a number of years prior to 1930 the petitioner was employed as manager of a branch store of J. C. Penney Co. at Modesto, California, under contracts which enabled him to purchase shares of stock of the company at prices less than their fair market value. In 1928 and 1929 he acquired under the contracts a number of shares of the stock at much less than their fair market value. He did not include in his income tax returns for those years any amount in respect of the acquisition of the shares. Held, that on the sale of some of the shares by the petitioner in 1930 and 1931 the basis for…

1Opinion of the Court

E. R. HAWKE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hawke v. Commissioner

Docket Nos. 76507, 76508.

United States Board of Tax Appeals

35 B.T.A. 784; 1937 BTA LEXIS 835;

March 31, 1937, Promulgated

1. For a number of years prior to 1930 the petitioner was employed as manager of a branch store of J. C. Penney Co. at Modesto, California, under contracts which enabled him to purchase shares of stock of the company at prices less than their fair market value. In 1928 and 1929 he acquired under the contracts a number of shares of the stock at much less than their fair market value.…

2Cases cited1 opinion

  1. Hawke v. CommissionerUnited States Board of Tax Appeals · 1937

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