Legal Opinion

Becker v. Commissioner

United States Tax Court

Decided August 12, 1966No. Docket No. 5135-64Published

Petitioner had an option to purchase shares of stock of his employer under a restricted stock option plan which required written notice to the company's treasurer at St. Paul, Minn., of his intention to exercise his option, together with full payment. On June 14, 1960, he placed his signed notice and check in the company mail at its Ridgefield, N.J., office, where he was employed.

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Petitioner had an option to purchase shares of stock of his employer under a restricted stock option plan which required written notice to the company's treasurer at St. Paul, Minn., of his intention to exercise his option, together with full payment. On June 14, 1960, he placed his signed notice and check in the company mail at its Ridgefield, N.J., office, where he was employed. This mail, in normal course by air mail, would reach the St. Paul office on June 15. The stock certificate was issued June 20. Petitioner sold the stock on the New York Stock Exchange on December 15, 1960. Held,…

1Opinion of the Court

George J. Becker and Isabelle Becker, Petitioners, v. Commissioner of Internal Revenue, Respondent

Becker v. Commissioner

Docket No. 5135-64

United States Tax Court

46 T.C. 613; 1966 U.S. Tax Ct. LEXIS 60;

August 12, 1966, Filed

Decision will be entered for the respondent.

Petitioner had an option to purchase shares of stock of his employer under a restricted stock option plan which required written notice to the company's treasurer at St. Paul, Minn., of his intention to exercise his option, together with full payment. On June 14, 1960, he placed his signed notice and check in the company mail at…

2Cases cited10 opinions

  1. Scott-Burr Stores Corp. v. WilcoxCourt of Appeals for the Fifth Circuit · 1952
  2. George W. S. Swenson and Ruth E. Swenson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
  3. Sullivan v. CommissionerUnited States Tax Court · 1948
  4. Swenson v. CommissionerUnited States Tax Court · 1961
  5. Hooper v. CommissionerUnited States Board of Tax Appeals · 1932

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