Legal Opinion

Omaha Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided January 18, 1934No. Docket No. 53237Published

Prior to 1918 the decedent was employed under contracts which, in addition to cash salary, gave him the right to purchase stock of his corporate employer at $50 per share.

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Prior to 1918 the decedent was employed under contracts which, in addition to cash salary, gave him the right to purchase stock of his corporate employer at $50 per share. The contracts were modified in 1918 to provide that decedent's account in respect of the stock should be credited with dividends declared thereon and if such dividends did not amount to $50 per share by stated times his account should be arbitrarily credited with sufficient amounts to make up the $50 on specified blocks of stock which would then be issued. In 1928, as the result of dividends and an arbitrary credit, 150…

1Opinion of the Court

OMAHA NATIONAL BANK, JOHN CLAPPER AND KATIE FARRINGTON, EXECUTORS OF THE ESTATE OF F. J. FARRINGTON, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Omaha Nat'l Bank v. Commissioner

Docket No. 53237.

United States Board of Tax Appeals

29 B.T.A. 817; 1934 BTA LEXIS 1475;

January 18, 1934, Promulgated

Prior to 1918 the decedent was employed under contracts which, in addition to cash salary, gave him the right to purchase stock of his corporate employer at $50 per share. The contracts were modified in 1918 to provide that decedent's account in respect of the stock should be…

2Cases cited1 opinion

  1. Omaha Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1934

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