Legal Opinion
Brown v. United States
District Court, D. Oregon
Decided October 17, 1968No. Civ. No. 67-283PublishedCited by 4 opinions
1Opinion of the Court
OPINION
SOLOMON, Chief Judge:
The residuary legatees of the estate of Clay Brown filed this action to recover additional income taxes which the Commissioner of Internal Revenue (Commissioner) assessed for the year 1956. The Commissioner taxed as ordinary income the difference between the acquisition price and the fair market value of stock which Mr. Brown (taxpayer) acquired by exercising an employee stock option. The Commissioner asserts that the option was not a “restricted stock option” within the meaning of Section 421 of the Internal Revenue Code of 1954, 26 U.S.C. § 421.
For a stock option…
2Cases cited6 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Robinson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1939
- Babbitt v. CommissionerUnited States Tax Court · 1955
- Building Syndicate Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1961
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Dorothy E. Brown and Donald Lee Brown and United States National Bank of Oregon, Etc. v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Kast v. CommissionerUnited States Tax Court · 1982
- Kast v. CommissionerUnited States Tax Court · 1982
- Schumann v. CommissionerUnited States Tax Court · 1983