Franklin v. Commissioner
United States Board of Tax Appeals
1. The petitioner, under his agreement of employment, was granted in 1927 an option to purchase 20,000 shares of stock of corporation A, his employer company, and was also granted, as an inducement to enter into such employment agreement, an option to purchase 20,000 shares of stock of corporation B, which controlled corporation A, in the event corporation A did not make available to petitioner 20,000 shares of its stock as provided in the employment agreement.
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1. The petitioner, under his agreement of employment, was granted in 1927 an option to purchase 20,000 shares of stock of corporation A, his employer company, and was also granted, as an inducement to enter into such employment agreement, an option to purchase 20,000 shares of stock of corporation B, which controlled corporation A, in the event corporation A did not make available to petitioner 20,000 shares of its stock as provided in the employment agreement. In January 1928 the petitioner, through his New York attorneys, caused to be organized corporation C and corporation D and assigned…
1Opinion of the Court
HAROLD B. FRANKLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ANNA MAY FRANKLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Franklin v. Commissioner
Docket Nos. 66716, 66717.
United States Board of Tax Appeals
34 B.T.A. 927; 1936 BTA LEXIS 624;
August 14, 1936, Promulgated
1. The petitioner, under his agreement of employment, was granted in 1927 an option to purchase 20,000 shares of stock of corporation A, his employer company, and was also granted, as an inducement to enter into such employment agreement, an option to purchase 20,000 shares of stock of…
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. IshamSupreme Court of the United States · 1873
- Bullen v. WisconsinSupreme Court of the United States · 1916
- Gano v. CommissionerUnited States Board of Tax Appeals · 1930
- L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
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