Legal Opinion

Hall v. Commissioner

United States Tax Court

Decided August 31, 1950No. Docket No. 21027PublishedCited by 15 opinions

Petitioner, who reported his income on the cash receipts and disbursements basis, was one of the organizers of a corporation in November 1942. In November 1942, he entered into an employment contract with the corporation under which he agreed to render services to it during the years 1943 and 1944. As part of his compensation, the corporation issued two certificates of stock in his name, each for 25 shares.

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Petitioner, who reported his income on the cash receipts and disbursements basis, was one of the organizers of a corporation in November 1942. In November 1942, he entered into an employment contract with the corporation under which he agreed to render services to it during the years 1943 and 1944. As part of his compensation, the corporation issued two certificates of stock in his name, each for 25 shares. He endorsed the certificates in blank and gave them to the treasurer of the corporation. Upon the satisfactory performance of the required services and pursuant to an order of the board of…

1Opinion of the Court

OPINION.

Harron, Judge:

The issue in this proceeding is whether petitioner is taxable in 1942 on the value of shares of stock issued in his name in that year, or in 1943 and 1944 when the shares were delivered to him upon his performance of personal services pursuant to an execu-tory contract with the Company.

Petitioner contends that he became the owner of the 50 shares in question in 1942 when the contract was signed by the parties and the si)ares were issued in his name; that the consideration for their issuance was the signing by him of the employment contract of November 25,1942; and that…

2Cases cited6 opinions

  1. Corliss v. BowersSupreme Court of the United States · 1930
  2. Brown v. HelveringSupreme Court of the United States · 1934
  3. Your Health Club, Inc. v. CommissionerUnited States Tax Court · 1944
  4. Jackson v. SmietankaCourt of Appeals for the Seventh Circuit · 1921
  5. McArdle v. CommissionerUnited States Tax Court · 1948

1 more not listed; retrieve them via the Exa API.

3Cited by15 opinions

  1. Estate of Ogsbury v. CommissionerUnited States Tax Court · 1957
  2. Worthy v. CommissionerUnited States Tax Court · 1974
  3. Bryan v. CommissionerUnited States Tax Court · 1951
  4. Hegra Note Corp. v. CommissionerUnited States Tax Court · 1966
  5. Estate of Bette v. CommissionerUnited States Tax Court · 1977

10 more not listed; retrieve them via the Exa API.

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