Legal Opinion
Thomas R. Pledger and Phyllis R. Pledger v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided April 2, 1981No. 79-3279PublishedCited by 27 opinions
1Opinion of the Court
LEWIS R. MORGAN, Circuit Judge.
In this appeal from the Tax Court decision, 71 T.C. 618, sustaining the Commissioner’s finding of deficiency, petitioner-appellant Pledger questions whether the full value of corporate stock purchased pursuant to an employee stock option and subject to certain securities restrictions can constitutionally be taxed as income under Section 83(a) of the Internal Revenue Code. The taxpayer also challenges the decision of the Tax Court that the term “any restriction” in section 83(a) includes the restrictions of an investment letter. Responding to these challenges, we…
2Cases cited18 opinions
- Weinberger v. SalfiSupreme Court of the United States · 1975
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Usery v. Turner Elkhorn Mining Co.Supreme Court of the United States · 1976
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
13 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Charles J. Martin v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
- Jackie L. And Janet G. McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
- Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Bagley v. CommissionerUnited States Tax Court · 1985
- Alves v. CommissionerUnited States Tax Court · 1982
22 more not listed; retrieve them via the Exa API.